BPCE - 2019 Universal Registration Document

RESPONSIBLE INTERNAL AND EXTERNAL PRACTICES NON-FINANCIAL PERFORMANCE REPORT

PROMOTING SUSTAINABLE, BALANCED RELATIONS WITH SUPPLIERS

The current whistleblowing procedure will be supplemented by the effective implementation of the obligations arising from the French Due Diligence Act in 2020. RESPONSIBLE PROCUREMENT POLICY CSR is one of the priorities of the 2020 procurement strategic plan followed by BPCE Procurement and the procurement function. The Group has set the following targets for 2020: increase the number of Group companies with Responsible • Supplier Relations and Procurement certification from 7 to 14; raise the percentage of requests for proposals (RFPs) • observing standardized procurement processes that include CSR criteria to 80%; pay suppliers in 28 days, on average; • incorporate CSR into the procurement policy. • ENGAGING STAKEHOLDERS WITH THE RESPONSIBLE PROCUREMENT POLICY Since 2018, the responsible procurement charter, a joint initiative by BPCE Procurement on behalf of Groupe BPCE and leading French banks and insurers, has been one of the reference documents included in tender documentation sent to suppliers. The aim is to involve suppliers in the application of diligence measures in this area. The CSR roadmap and the action plan produced by the “developing responsible procurement” project implemented under the Groupe BPCE CSR policy, set out three priority objectives: optimizing the environmental and social impact of purchases, contributing to the economic and social development of the regions and promoting best business practices. A responsible-procurement working-group run by BPCE Procurement and comprising procurement and CSR representatives discusses these three objectives and implements the action plan. CSR is incorporated: in the Groupe BPCE procurement policy: developing • responsible procurement is one of the three priorities of the Group’s procurement policy; in the procurement process: the responsible procurement • policy has been adapted and included in the different tools used in the procurement process; in supplier relations: analysis considered how to find a simple, • quantifiable way of measuring suppliers’ CSR performance. Procurement teams can include a voluntary CSR performance assessment questionnaire for suppliers and their products in order to identify CSR risks and opportunities in the tender process and incorporate this performance in their overall assessment; in procurement documents: A the end of 2019, 36% of tender • documentation included a CSR component, up 6% compared to 2018. The Group’s procurement managers are instructed to apply and circulate this policy within their companies and among their supplier panels. APPLYING THE RESPONSIBLE PROCUREMENT POLICY IN DAILY PROCUREMENT ACTIVITIES

In 2019, two Groupe BPCE companies – Banque Populaire du Sud and Caisse d’Epargne Hauts de France – applied for the Responsible Supplier Relations and Procurement label in cooperation with BPCE Procurement. The companies certified in 2016 – Banque Populaire Rives de Paris, Caisse d’Epargne Ile-de-France and Caisse d’Epargne Midi-Pyrénées – have renewed their certification for three years. As part of a program of constant improvements, the companies certified in 2018 and 2019 – Banque Populaire Grand Ouest, Caisse d’Epargne Aquitaine Poitou-Charentes, Caisse d’Epargne Bretagne Pays de Loire, Caisse d’Epargne Grand Est Europe, Caisse d’Epargne Rhône Alpes and BPCE – received a positive assessment in their annual review. In line with the Responsible Supplier Relations Charter and the responsible procurement standard ISO 20400, the Responsible Supplier Relations and Procurement certification is awarded by the company mediator (under the auspices of the French Ministry for the Economy) and the CNA (French association of purchasing managers). It aims to single out French companies that have established lasting, balanced relations with their suppliers. The certification is awarded for a period of three years and an annual audit is performed to verify that best practices in responsible supplier relations (respect for supplier interests, integration of environmental and social criteria in procurement procedures, quality of supplier relations, etc.) are constantly applied by the certified entities. Eleven Groupe BPCE companies have committed to this label, reflecting the responsible procurement strategy coordinated by BPCE Procurement and the integration of CSR at the center of the procurement function and in relations with suppliers. RAISING AWARENESS OF RESPONSIBLE PROCUREMENT In 2019, two e-learning training courses on ethics in procurement and responsible procurement were published for the procurement and CSR departments. A platform for sharing services, suppliers and best practice – ONEMAP RSE – was made available to Groupe BPCE employees. The objective is to allow localized sourcing, taking CSR criteria into account. An event on payment deadlines was organized by BPCE Procurement. It allowed purchasers, Accounting and Finance departments in the Group companies to share their payment rules and use testimonials to identify best practices. DUE DILIGENCE ACTION PLAN The initiatives implemented in accordance with parent company and client company due diligence requirements are detailed in section 2.4.1 of this chapter, “Due diligence obligations”. Outlook The Group aims to continue to apply the action plan provided for in the CSR pillar of the 2020 procurement strategic plan, in line with the “Developing responsible procurement” priority set out in the CSR section of the Group strategic plan. Appropriation of the responsible procurement policy will continue with the dissemination of best practices, the implementation of the supplier CSR assessment shared by procurement and CSR managers, and the awarding of the Responsible Supplier Relations and Procurement certification to new Group companies.

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UNIVERSAL REGISTRATION DOCUMENT 2019 | GROUPE BPCE