BPCE - 2019 Universal Registration Document

RESPONSIBLE INTERNAL AND EXTERNAL PRACTICES NON-FINANCIAL PERFORMANCE REPORT

Responsible internal and external practices 2.4

2.4.1

Respecting business ethics

THE GROUPE BPCE CODE OF CONDUCT AND ETHICS

https://www.natixis.com/natixis/jcms/rpaz5_65439/en/code-of- conduite

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Groupe BPCE published a code of conduct and ethics in 2018, as announced in the TEC 2020 strategic plan. It was reviewed by the Cooperative and CSR Committee then approved by the Executive Management Committee and the Supervisory Board. http://guide-ethique.groupebpce.fr/ The Code is rooted in international values and standards, and provides a practical guide with clear illustrative examples. It includes a message from Executive Management and sets out the Group’s ethical standards in three areas: the interests of customers, employer responsibility and social responsibility, with practical business-oriented examples. The Code applies to all members of staff in all Groupe BPCE entities. In view of its specific activities, Natixis also published a code of conduct in early 2018 – a master document setting out the main guidelines to be followed by employees in their relations with Natixis’ stakeholders: its clients, teams and shareholders, as well as society at large.

GUIDING PRINCIPLES These rules of conduct are illustrated with real-life situations that may be encountered by any stakeholder, including employees, managers, directors and other parties. When contradictory influences are at play, it is important that employees have clear rules to help them make the right decision. The code of conduct and internal policies and procedures provide clear instructions on how to behave, but they cannot provide a solution for all situations. Members of staff must exercise their judgment to make the right decision, drawing on the principles set out in the code of conduct. If they have any doubts about what they are about to do, employees should ask themselves the following questions:

Is it legal?

No?

WHISTLEBLOWING

Yes Yes Yes Yes

Groupe BPCE employees can use the internal whistleblowing procedures in place in all Group entities to report

No?

Does it observe our policies and procedures?

breaches of the rules before they become serious risks.

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

No?

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.

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?

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UNIVERSAL REGISTRATION DOCUMENT 2019 | GROUPE BPCE