BPCE - 2018 Registration document

2 NON-FINANCIAL PERFORMANCE REPORT Sustainable and responsible value creation

Groupe BPCE prepares transfer pricing documentation for its intragroup transactions to comply with local transfer pricing documentation requirements in the countries where its entities are located. Transfer pricing tax compliance French legislation requires the completion of several specific tax returns and disclosures on transfer pricing. In December 2018, Groupe BPCE adhered to the new Country-by-Country (CbC) report, including data taken at December 31, 2017. This new report was created in accordance with Action 13 of the OECD’s Base Erosion and Profit Shifting (BEPS) action plan – a coordinated international approach to combat tax evasion by multinational enterprises. The French General Tax Code requires the arm’s length principle be applied to intragroup transactions. Groupe BPCE entities are subject to regular tax audits during which the authorities review the compliance of its transfer pricing policy. Financial institutions are also subject to specific annual reporting requirements (under the European CRD IV Directive), calling for an itemized disclosure of corporate tax paid in all countries of operation. This report is included in Groupe BPCE’s annual registration document. No commercial presence in non-cooperative states or territories Groupe BPCE does not conduct any business in non-cooperative countries and territories and has no registered offices in these countries. The French tax authorities publish a list of non-cooperative states or territories pursuant to Article 238 0 A of the General Tax Code. The latest list includes the following countries: Botswana, Brunei, Guatemala, Marshall Islands, Nauru, Nioué, Panama. Governance and supervision of products and CSR analysis of new products and services When Groupe BPCE was founded in September 2010, it established an approval procedure for new banking and financial products and services aimed at customers of both networks. This procedure primarily aims to ensure that the risks associated with sales of products and services to customers are adequately managed. It does so by ensuring that all relevant regulatory requirements, in particular those intended to protect customer interests and personal data, are factored in to the design, promotional documents and terms of sale of each product while still meeting customer requirements. The importance of protecting customer interests and data has grown with the development of digital services and applications in the banking and financial sector (in particular pursuant to the General Data Protection Regulation, which took effect on May 25, 2018). The procedure draws on BPCE’s various areas of expertise (including in particular legal, finance, risk, information systems, compliance, taxation, security). Contributions from experts in these areas are presented to the Review and Validation Committee for New Groupe RESPONSIBLE MARKETING AND CUSTOMER PROTECTION

BPCE Products (CEVANOP), and all aspects of each new product or service (or updates, as applicable) must be approved before it can be brought to market. This procedure is implemented by the central institution for both networks. In addition, each network defines its own new product/service procedure, aimed at ensuring that the Group product and service range is properly integrated in the operating methods of the network institutions, and that products sold to customers meet their requirements while keeping risks under control. This requires appropriate training for advisors and CRMs alike. A similar procedure also applies to the sales process (particularly the remote selling process) and to the materials used to promote products and services to the Group’s customers on a regular basis. The Compliance function coordinates the approval of national sales challenges, ensures that conflicts of interest are managed properly and guarantees that customer interests always come first. Compliance is careful to ensure that sales procedures, processes and policies guarantee that compliance and ethics rules are observed at all times for all customer segments, and in particular that customers are given suitable advice with respect to their situation and their needs. The Group has not implemented a systematic CSR labeling scheme covering all of its banking products. Products with major CSR implications, environmental products and social and solidarity-based products belong to a separate range to make them easily identifiable for customers, including Mirova’s range of investment funds and SME finance funds, particularly for innovative SMEs (FIPs – local investment funds, FCPIs – innovation investment funds, see Chapter 6.2.1 “Responsible investment”). Transparency of the product offer The Group places great importance on keeping customers properly informed through branch displays and contractual, pre-contractual and commercial documents. Group institutions have been provided with a compliance guide listing all their associated obligations. In addition, the product governance procedure ensures that all commercial documents are validated beforehand by the Compliance and/or Legal division. To ensure that all employees fully understand the importance of preventing these risks, they are specially trained in banking law (customer protection: banker’s duty to advise, protection against over-indebtedness, etc.), the right to hold an account, and vulnerable customers. Customer protection The Group’s reputation and the trust of its customers are strengthened when the products and services it sells comply with regulations and the information it supplies is reliable. To maintain this trust, the Compliance division makes customer protection a top priority. To that end, Group employees regularly receive training on customer protection issues to maintain the required level of customer service quality. These training sessions are aimed first and foremost at promoting awareness of compliance and customer protection among new hires and/or sales team employees. Additionally, ethics and compliance training, entitled “Fundamentals of professional ethics”, has been set up for all Group employees.

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Registration document 2018