BPCE - 2019 Universal Registration Document

RESPONSIBLE INTERNAL AND EXTERNAL PRACTICES NON-FINANCIAL PERFORMANCE REPORT

Subject

Mitigating measures

Monitoring indicator

Preventing discrimination and promoting equal opportunities for men and women

See Chapter 2.3.2, “Promoting personal and professional microloans in partnership with support networks” See Chapter 2.3.2, “Financing for the energy, ecological and social transition with Groupe BPCE’s products and services” and Chapter 2.2.1, “Engagement and dialog”

Women accounted for 49% of entrepreneurs supported with a professional microloan by the Banques Populaires and the Caisses d’Epargne ( via our partner France Active) It is not possible to report on visible minorities because this would involve the application of criteria requiring the production of sensitive data under the terms of the GDPR

Promoting equal opportunities for visible minorities

Data security and confidentiality

See Chapter 2.4.1, “Data protection and cybersecurity” Percentage of new community projects with ISS and Privacy support: 87%

More generally, as part of its business as a banker, Groupe BPCE is subject to a series of regulations (anti-money laundering, anti-corruption, embargoes, etc.) which form an integral part of its activity. Over and above these requirements, ESG criteria are gradually being incorporated into the Group’s risk policies to take into account the impact of the activities it finances. A section on climate risk and strengthening CSR principles was added to the Group’s credit risk policy in 2018. A new paragraph on the ESG risk assessment and ratings (high, moderate, or low risk) has also been added to supplement sector policies (agri-food, automotive, construction and public works, communications and media, transport sectors, etc.). The non-financial performance report addresses this risk under “ESG risks” (see Chapter 2.3.1, “Reflecting environmental, social and governance risks and our customers’ requirements and aspirations in our strategy”). In its financing activities, for several years now, Groupe BPCE, including Natixis, has addressed the human rights and environmental risks incurred by some of its financing activities, most notably by applying the Equator Principles for project financing and specific policies for sensitive sectors. (See Chapter 2.2.1, “Engagement and dialog” and Chapter 2.3.1, “Reflecting environmental, social and governance risks and our customers’ requirements and aspirations in our strategy”.) As a signatory of the Equator Principles, for the past several years, Natixis has applied a system for measuring and managing risks related to human rights and the environment in its project financing activities. It also applies specific sector policies in high risk sectors. In addition to this due diligence, Natixis is also working on an integrated approach to managing environmental, social and governance (ESG) risks for its corporate clients. The process is being included in the bank’s existing client onboarding and loan approval systems, involving the business lines and the Compliance, Risk and CSR departments. This project will use questionnaires specific to each sector rolled out gradually among existing and new customers to establish a ranking of clients based on due diligence categories. Procurement pillar In a concerted approach, BPCE Procurement, acting on behalf of Groupe BPCE, and three other banking groups decided to map out their CSR risks by procurement category using shared classifications covering around a hundred sourcing categories. The CSR risk map and the corresponding due diligence plan were presented to the procurement and CSR functions in the last quarter of 2018. The map identifies risks of serious violations and prioritizes the necessary actions in each category. It also incorporates the risk associated with the country in which

the majority of the added value on each product or service is generated. This risk map identified thirteen procurement categories with a high or very high level of risk independent of country risk, which can increase or decrease the intrinsic risk. For these categories, a specific procedure has been set up for proposal requests organized by BPCE Procurement on behalf of Group companies. Under this procedure, suppliers must complete a questionnaire specific to each category and provide details of the action taken to mitigate the risks and prevent major violations. BPCE Procurement assesses these actions and assigns a CSR rating, which is included in the supplier’s overall rating. Depending on the results, an improvement plan is established with the chosen suppliers, subject to review at the six-month point. This system can be used outside the consultation process for suppliers already approved or those that invoice large amounts to Groupe BPCE. Procurement managers at Groupe BPCE entities may apply this due diligence system on a voluntary basis and can contact their CSR manager to prepare a joint action plan. BPCE Procurement has provided training to familiarize the procurement and CSR functions with the system, in the form of morning procurement meetings, classroom-based lessons and specific due diligence e-learning courses. Indicators are used to monitor the rollout of the due diligence process for high and very high risk procurement categories: 31% of relevant procurement categories have been assessed; • 46% of relevant procurement categories are currently being • assessed; 100% of BPCE Procurement buyers responsible for these • procurement categories have received training. Whistleblowing Groupe BPCE has a whistleblowing system in place setting out the applicable procedure at all Group entities, as provided for in the act of December 9, 2016 (Sapin 2 Act) and the Ministerial Order of November 3, 2014 on internal control of banking sector companies. The current whistleblowing procedure applies to all internal employees, as well as to external and occasional staff, who may use the procedure should they become aware of any crime, offence, major violation of the law, threat or major breach of general interest or any conduct or situation that breaches the code of conduct. Groupe BPCE entities protect whistleblowers. Under no circumstances may they be subject to any disciplinary action or legal proceeding, provided they have acted impartially and in good faith.

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UNIVERSAL REGISTRATION DOCUMENT 2019 | GROUPE BPCE

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