BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

FINANCING OF PUBLIC LIFE AND REPRESENTATION OF INTEREST FINANCING OF PUBLIC LIFE Groupe BPCE does not directly support any specific political party, whether in the form of donations, sponsorship or any other means. The Group respects strict neutrality in political matters. On the other hand, as a leading banking player in France, Groupe BPCE institutions contribute to the financing of public life, in accordancewith the strict legislative and regulatory framework existing in France in this area, and in compliance with the rules on KYC, Anti-Money Laundering (AML), and Politically Exposed Persons (PEP). Its involvement is therefore at two levels: As account keeper: the Group’s institutions comply with the obligations of Articles L. 52-6 and L. 52-6-1 of the French Electoral Code, which stipulate in particular that any fiscal agent appointed by their candidate during an election campaign is entitled to open a campaign account, and to the necessary means of payment as supplied by the bank keeping the account. This principle is applied directly by the banking institution when it has accepted the opening of an account, or as part of a forced Banque de France procedure. As a reminder, the control of this right to hold an account is ensured in France by the ACPR (French Prudential Control Authority). Finally, it should be noted that the accounts of the proxy holder at the end of the election are appended to the candidate’s campaign account, which will ultimately be submitted to the control of the National Commission for Campaigns and Political Financing (CNCCFP); As a provider of financing: via loans granted to candidates who are natural persons who have applied to the institution. These loans are granted in accordancewith the rules in force in banks, in accordance with national and European legislation and regulations. In this respect, as with all loans, our institutions apply a risk and responsible lending policy, combined with an analysis of the borrower’s creditworthiness, its personal ability to repay and a guarantee (personal or third-party, real property, pledging of securities, borrower insurance, etc.). In addition, due to the specific nature of the financing, the institutions also take into account the expenditure ceiling, as well as the uncontrollable risk of invalidation of campaign accounts and non-reimbursementto the candidates concerned of a portion of the costs by the French government. Lastly, as with account management, institutions ensure compliance with anti-money laundering and Politically Exposed Persons (PEP) rules. Lastly, Groupe BPCE is in constant contact with the mediation of loans to candidates and political parties set up by Article 28 of Law No. 2017-1339 ofSeptember 15, 2017, for Trust in Political Life. REPRESENTATION OF INTERESTS As a cooperative bank committed to serving its customer- shareholders, in the very heart of the regions, Groupe BPCE’s institutions intend to make a constructive contribution to the public debate by providing decision-makersand civil society with information on socio-economicchanges at the regional, national or international level, as well as in the banking sector and its developments.BPCE’s objective is to actively contribute to the space for reflection and to participate as a stakeholder in collective, fair and informed decision-making. Groupe BPCE’s lobbying initiativesare thereforestrictly within this framework.In terms of lobbying, in additionto respectingits ethical rules and its cooperative values, BPCE applies all the regulations in force, as well as all the codes of ethics with which its public contacts, and the various financialmarket associationsof which it is a member, are required to comply.

TRANSFER PRICING TAX COMPLIANCE French legislation requires the completion of several specific tax returns and disclosures on transfer pricing. At the end of the 2020 fiscal year BPCE signed the new country-by-country statement for fiscal year 2019. This report was created for the implementation of Action 13 of the OECD called BEPS (Base Erosion and Profit Shifting) for a coordinated international approach to combating tax evasion by multinational companies. The French General Tax Code requires the arm’s length principle be applied to intragroup transactions. Groupe BPCE entities are subject to regular tax audits during which the authorities review the compliance of its transfer pricing policy. Financial institutions are also subject to specific annual reporting requirements (under the European CRD IV directive), calling for an itemized disclosure of corporate tax paid in all countries of operation. This report is included in Groupe BPCE’s annual registration document. MINOR COMMERCIAL BUSINESS IN NON-COOPERATIVE STATES OR TERRITORIES Groupe BPCE conducts minor amounts of commercial business in Panama, Oman, Fiji, Vanuatu and the Bahamas, considered non-cooperative countries and territories. Every year, the French tax authorities publish a list of non-cooperative states or territories pursuant to Article 238-0 A of the French General Tax Code. The latest list published per the decree of January 6, 2020 includes the following countries and territories: Vanuatu, Fiji, Guam, the US Virgin Islands, Oman, American Samoa, Samoa, and Trinidad and Tobago. IMPLEMENTATION OF DIRECTIVE (EU) 2018/822 ON THE AUTOMATIC AND MANDATORY EXCHANGE OF INFORMATION IN THE TAX FIELD IN RELATION TO CROSS-BORDER ARRANGEMENTS THAT MUST BE DECLARED (KNOWN AS “CAR 6”) This directive requires any person who designs, organizes or markets a potentially aggressive cross-border tax planning scheme to declare it to the tax authorities of their country within a period of 30 days. In practical terms, financial institutions must conduct due diligence to determine their obligations when acting on their own behalf or for their clients. This new reporting obligation, applicable from July 1, 2020, has been postponed for six months due to the Covid-19 crisis. The Group has developed a general methodology for applying the rules laid down by this regulation for Groupe BPCE establishments located in France.

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE

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