BPCE - 2019 Universal Registration Document

RESPONSIBLE INTERNAL AND EXTERNAL PRACTICES NON-FINANCIAL PERFORMANCE REPORT

ORGANIZATIONAL STRUCTURE In accordance with Groupe BPCE’s charters, each institution has its own financial security unit. A department within the Risk division coordinates anti-money laundering and counter terrorist financing processes. It determines the financial security policy for the entire Group, establishes and obtains approval for standards and procedures, and ensures that money laundering and terrorism financing risks are taken into account in the Group’s procedures for approving new products and services. SPECIALIZED PROCESSES In accordance with regulations, the banks have methods for detecting unusual transactions that are specific to each risk classification. These can be used, if needed, to conduct closer analysis and to submit suspicious-transaction reports to Tracfin (French financial intelligence agency) as promptly as possible. The Group’s risk classification identifies “high-risk” countries in terms of money laundering, terrorism, tax fraud or corruption. It enhanced its systems in 2018 with the introduction of a set of standards and automated scenarios tailored to the specific features of terrorist financing. As regards compliance with restrictive measures related to international sanctions, Group institutions are 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). SUPERVISION OF OPERATIONS Internal reports on the prevention of money laundering and terrorist financing are submitted to company directors and governing bodies, as well as to the central institution.

The Group code of conduct and ethics was widely rolled out from late 2018 and throughout the first half of 2019, accompanied by a communications plan across all the Group’s media. All members of staff must complete a mandatory e-learning course by the end of the first quarter of 2020 to confirm their understanding of the principles set out in the Code. At the end of 2019, 84% of staff had done the course. Work is also under way to set up an ethical governance structure with a specific reporting process, to incorporate ethics in HR processes and to ensure consistency between the code of conduct and ethics and internal procedures. This work should be finalized in the first half of 2020. Financial security covers anti-money laundering and counter terrorist financing measures, as well as adherence to international sanctions aimed at individual persons, entities or countries. BPCE works to prevent money laundering and terrorist financing through: CORPORATE CULTURE Promoted across all levels of the company, corporate culture is built on: formally-established principles governing relationships with • customers designed to avert risks; employees are regularly reminded of these principles; a harmonized, biannual training program for Group employees, • and specialized training for the Financial Security function. PREVENTION OF MONEY LAUNDERING AND FRAUD

ACTIVITIES IN 2019 The Group Financial Security department increased its headcount so it can actively monitor all Financial Security matters. The permanent control system was reviewed and enhanced.

ANTI-MONEY LAUNDERING

Change 2018-2019

2019

2018

2017

Percentage of employees trained in their entity’s anti-money laundering policies and procedures (based on reports from the entities) (1)

77%

79%

90%

(3%)

Number of employees (on permanent, fixed-term or work-study contracts) who have received anti-money laundering training in the last two years. (1)

ANTI-CORRUPTION MEASURES PREVENTION OF CORRUPTION

Compact, whose tenth principle states that “Businesses should work against corruption in all its forms, including extortion and bribery.” Anti-corruption measures The Group strives to prevent corruption in order to guarantee the financial security of its activities, in particular by: taking measures against money laundering, terrorist financing • and fraud, supervising politically-exposed persons, and complying with embargoes;

Corruption, which is defined as an act in which a person offers or grants an undue reward to another person in exchange for an act falling within that person’s remit, is fraudulent and unethical behavior subject to severe criminal and administrative sanctions. Groupe BPCE denounces corruption in all forms and in all circumstances. It is a signatory of the United Nations Global

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UNIVERSAL REGISTRATION DOCUMENT 2019 | GROUPE BPCE

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