BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

In 2020, as part of its banking inclusion policies, Groupe BPCE strengthened its support system for financially vulnerable customers, in accordance with the decree of July 20, 2020. Employee training Group employees regularly receive training on customer protection, the right to hold an account and vulnerable customers. Training on the Group's Code of ethics and compliance, entitled “Fundamentalsof professional ethics”, has been set up for all employees. Supervision of sales challenges Group Compliance coordinates the approval of national sales challenges, ensures that conflicts of interest are managed properly and guarantees that customer interests always come first. Local challenges are coordinated by local Compliance teams. Addressing market abuse and financial activities With the transposition of the Market Abuse directive and regulation, the Group began using a market abuse alert analysis and reporting tool covering the Banques Populaires, the Caisses d’Epargne and their subsidiaries. A virtual assistant helps staff members analyze alerts reported by the Group’s information systems. The Group’s market abuse memorandumhas been updated and compliance staff are given special training to enhance their skills and due diligence in the analysis of market abuse alerts. Lastly, the SRAB KPI measurement methods (regarding the separation of banking activities) recommended by the AMF and ACPR were implemented throughout the Group. COMPLAINT MANAGEMENT The complaints handling process Complaints are handled at three successive levels: level 1: the branch or business center in charge of the • relationship; level 2: the Customer Relations department of the bank or the • subsidiary if the complaint has not been resolved at level 1; level 3: the mediator, if the complaint persists despite the • level 2 intervention. The mediator is an independent body. It has its own website. A form allows clients to submit their requests for mediation. All Groupe BPCE entities have a department that handles customer complaints. The procedure for discussing or transferring complaints between the Customer Relations departments of Group institutions, and those of the subsidiaries, is organized to ensure that each complaint is addressed as quickly as possible.

In terms of banking and insurance product monitoring, five committees were held in the fourth quarter of 2020: BTC daily banking, BtC (business to customer) loans, BtC bank savings, non-life insurance and BtB (business to business) banking products. The purpose of these committees is to constantly monitor the marketing of products throughout their life cycle in order to guarantee that the interests, objectives and characteristics of the customer initially targeted at the time of their approval continue to be duly taken into account. 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). Remediation has continued since the entry into force of these regulations. The governance and monitoring of products introduced by MIF2 and DDA resulted in the implementation of: a committee for the validation of model portfolios relating to • financial instruments led by the Retail Banking and Insurance division (BPA): monitoring the performance of risky asset pockets, macroeconomic review, allocation analyses and outlook; a Product Governance and Supervision Committee working • alongside manufacturers to exchange information between manufacturersand distributors, and to oversee complaints and the distribution strategy in line with sales reporting, product changes and investor protection, etc. For 2020, this committee met on October 2; 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, Groupe BPCE has a system for approving national sales material, which includes approval by the Compliance department, Legal department and Tax department, where applicable. Local communications are validated by the Group’s establishments, which have at their disposal documentation listing the obligations in this area (standards and “essential” sheets). 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. With regard to CSR offers (environmentalproducts and solidarity and social products), the Group has set up a specific range of financial products. It should be noted that since 2018, several European consultations related to sustainable finance and the incorporation of ESG criteria (in particular in product governance but also in client advice) have been launched. The AMF has also drawn up doctrines: the Position recommendation 2010-05 updated in October 2018 andintroducing an exemption from criterion No. 4 for products on ESG-themed indices; position recommendation 2020-03 details the information related to the considerationof extra-financial criteria that may be communicated by French collective investment schemes and foreign UCITS authorized for marketing in France (provisions set out in the various regulatory and commercial documents).

2

101

UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE