BPCE - 2019 Universal Registration Document

NON-FINANCIAL PERFORMANCE REPORT

CSR REPORTING METHODOLOGY

REPORTING TOPICS The following topics are considered relevant in terms of the bank’s indirect impacts: circular economy, reducing food waste, combating food poverty, improving animal welfare and ensuring responsible, fair, sustainable food supplies. These topic are not addressed in specific paragraphs in this report but are covered by the bank’s ESG risk analysis procedures. For its lending business, these topics are covered in sector policies. For investment and asset management activities, they are covered by the ESG ratings methodologies for fund management. The matrix used to rate the 21 CSR risks provides a rating system for gross risks based on their frequency and severity over a three-year period. It also measures the Group’s net risk exposure in terms of the risk management systems (processes/quality, resources, controls) used. User Guides The user guide, addressed to all contributors to the Group CSR reporting processes, was updated for 2019. With respect to the Group’s registration document (but also for each entity, i.e. annual management report or registration document), it defines the following: the regulatory environment; • the timeline; • the reporting process (scope, rules on extrapolation for • incomplete data, consolidation rules and the information control process); a glossary. • This guide also relies on a CSR reporting standard that specifies all of the indicators published, their definitions, their units, the corresponding GRI reference, their sources, how they are calculated and collected, and examples of controls to carry out. The Group carbon-review user guide was also updated in 2019. The guide is intended to promote the carbon-review system. The purpose of this guide is to: present the general principles of the method developed by the • Group; review the system’s history and the most recent changes to • the system; ROLE OF METHODOLOGY TOOLS Risk analysis matrix

offer a uniform presentation of the reporting rules for Groupe • BPCE’s greenhouse gas emissions reviews (reporting period, scope, extrapolation rules, etc.); enable departments to establish action plans for carbon • reduction while meeting the requirements of Article 75 of the Grenelle 2 Act, which concerns greenhouse gas emissions reviews and the Local Climate-Energy Plan (“PCET”) plan. In 2019, the Group published three methodology memos for Travel, Fixed Assets and Procurement. Reporting period Published data cover the period from January 1, 2019 to December 31, 2019. Where physical data are not comprehensive for the period, contributors make approximate calculations to estimate the value of the missing data from average ratios provided by Groupe BPCE (in the user guides) based on FTEs and/or the surface area covered. The contributors review the estimates used and send their comments along with the information provided and approved by the Group. Comparability For 2019, Groupe BPCE chose only to report figures for a single year for some indicators, namely those that have undergone a major change in definition since 2018 and some that were newly introduced in 2019. Controls The “ESG information quality control framework” defines the organization of control systems for ESG information within Groupe BPCE, and describes the main policies in place on this subject. It applies to all Groupe BPCE entities in the consolidated scope: the central institution, its direct and indirect subsidiaries, all BPCE affiliates and their subsidiaries. Each entity is responsible for the accuracy of its CSR data. The same applies to Groupe BPCE’s operational divisions. At Group level, all data collected are verified and subject to a careful review of units and data consistency. Contributors are asked for an explanation where figures appear unjustified. The third level of control is the Internal Audit, which performs checks on entities’ CSR reporting as part of its multi-annual audit plan (since 2017). If any data published in the management report for the previous year prove inaccurate, a correction is made with an accompanying explanation on the bottom of the same page.

Reporting scope for 2019 2.5.2

HUMAN RESOURCES INDICATORS – REPORTING SCOPE In 2019, the reporting scope reviewed for human resources indicators (excluding training and absenteeism) included the following:

Groupe BPCE’s long-term objective is to meet the regulatory requirement of producing CSR reporting for the statutory scope of consolidation (the same as used for the publication of the Group’s consolidated financial statements). The scope established for 2019 was defined as reasonably as possible under the circumstances. This scope varies depending on the type of indicator. The scope will expand every year, with the aim of covering the entire statutory scope of consolidation.

the Banques Populaires; • the Caisses d’Epargne; • Banque de Savoie; •

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UNIVERSAL REGISTRATION DOCUMENT 2019 | GROUPE BPCE

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