BPCE - 2019 Universal Registration Document


SUB-CONTRACTING POLICY In accordance with the responsible procurement policy, the Group’s suppliers are required to comply with current CSR rules and regulations and to encourage their own suppliers and sub-contractors to do the same. These commitments are included in the responsible procurement charter, which is one of the reference documents included in RFP documentation. DISABILITY AND RESPONSIBLE PROCUREMENT POLICY (“PHARE”) Since July 2010, when it launched the responsible purchasing and disabilities policy ( Politique Hanidcap et Achats Responsables, or PHARE), Groupe BPCE has contributed to the professional and social inclusion of persons with disabilities by sub-contracting some operations to companies working with disabled persons. In 2019, Groupe BPCE bolstered this commitment by spending €15 million (including tax) (1) on companies employing persons with disabilities, representing a more than five-fold increase since the policy was launched. Purchases by Groupe BPCE from companies working with disabled persons contributed to the professional inclusion of persons with disabilities equivalent to 499 Full-Time Equivalent (FTE) positions (1) . To develop purchasers’ expertise and independence when purchasing from CUSTOMER PROTECTION Groupe BPCE protects its customers’ interests by tasking committees with the approval of new products, services and sales processes and any upgrades. In 2010, Groupe BPCE introduced an approval procedure for new banking and financial products and services. This procedure is designed to manage the risks associated with the sale of products and services and the implementation of new sales processes (digitalization, etc.) and to take into account regulatory requirements aimed at protecting customers’ interests and personal data. The approval procedure includes contributions from the competent experts and business lines within BPCE. This procedure must be completed before the new product or sales process is presented to the Group’s approval committees prior to marketing or development. Within the scope of investment services, BPCE’s marketing process incorporates the obligations arising from the Markets in Financial Instruments directive and regulation (MiFID II), the Insurance Distribution Directive (IDD) and the Packaged Retail Investment and Insurance-based Products Regulation (PRIIPs). A remediation plan was set up in 2018 and continued in 2019 to enhance IT security in some processes. Accordingly, specific governance and supervision of products covered by MiFID II have resulted in the establishment of: a committee in charge of validating model securities • portfolios, which meets quarterly since the third quarter of 2018 to monitor the performance of high risk asset allocations, perform a macroeconomic review and prepare an allocation analysis and outlook; Number of full-time equivalent positions in companies working with disabled persons (2019 estimate) Purchases from companies working with disabled persons (2019 estimate) (in thousands of euros) Estimate. (1) PURCHASES FROM COMPANIES WORKING WITH PEOPLE WITH DISABILITIES

companies working with people with disabilities, an e-learning training course was made available to the procurement function and the Group’s disability officers. Groupe BPCE currently works with over 300 suppliers in this sector who provide different types of services both directly and via co-contracting agreements. With this policy, the Group has undertaken to continue expanding its cooperation with EAs (entreprises adaptées), which are companies offering disability-friendly work environments, and with ESATs (établissement et service d’aide par le travail), which are establishments offering employment to disabled persons with special needs and unable to work in an ordinary setting. The PHARE symposium aims to facilitate meetings between companies working with disabled persons and Group companies in order to encourage them to work more often with EAs and ESATs. This annual event also provides the opportunity to share best practices and thus facilitate the implementation of new initiatives. In 2019, four Group entities attended the fifth symposium held in south-eastern France. The theme of the symposium was innovation, providing an opportunity to learn about new activities offered by companies in the social and solidarity-based economy and start-ups in the region.

2019 (1)









a Product Governance and Supervision Committee working • alongside manufacturers, established in 2019 to exchange information between manufacturers and distributors, and to oversee complaints and the distribution strategy in line with sales reporting, product changes and investor protection, etc.


BPCE has published a code of conduct and ethics for the whole Group. Employees have been informed about the Code and it is available on the Intranet and on Internet. http://guide-ethique.groupebpce.fr/ Providing customers with clear, accurate and truthful information The Group ensures it provides its customers with accurate information (in-branch displays; contractual, pre-contractual and commercial documentation; product subscription process). To this end, BPCE has a system for approving national sales material, which includes approval by the Compliance division and the Legal department, where applicable. Local communications campaigns are approved by the Group’s banks, which have been provided with a compliance guide listing all their obligations in this area. Compliance is careful to ensure that sales procedures, processes and policies guarantee that compliance and ethics rules are observed at all times for all customer segments, and in particular that customers are given suitable advice with respect to their situation and their needs.

(1) Estimate.




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