BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

GOVERNANCE, METHODOLOGY AND SCOPE OF THE DUE DILIGENCE PLAN In view of the issues covered by the due diligence system and the scope of risks covered, a number of divisions were involved in drafting the due diligence plan: CSR, Risks, Compliance and Permanent Control, Human Resources, Procurement, and Legal, as well as representatives from Natixis, a BPCE subsidiary also subject to the law on due diligence. The study of the main risks that may result from its activities has enabled us to select two mapping universes: • one related to the operation and activities of BPCE and its subsidiaries, addressed in the “Activities” pillar (namely, its employees and its main activities as a banker); • the other specific to the Procurement function, addressed in the “Procurement” pillar ( i.e. its suppliers and subcontractors). In light of these identified risks, and given the obligation to provide results, reasonable due diligence measures intended to prevent the risks were identified and/or enhanced. The overall rollout of the due diligence plan is coordinatedby the divisions listed above and implemented under their responsibility. The plan is designed to adapt over time as new issues and risks are identified. As part of the development of its due diligence action plan, the following issues were identified: Discrimination, infringement of equality, respect for private and family life, the right to strike, freedom of assembly and association as well as infringement of freedom of opinion; Health-related risk, failure to observe legal working conditions, forced labor, child labor, violation of worker safety, and unequal access to healthcare; Risk of pollution (water, sea, soil), undermining the fight against global warming, damage to biodiversity, waste management. As part of the management of its employees, BPCE is aware that its primary area of responsibility is internal and therefore pursues a responsible policy with its employees, most of whom are located in France. These issues are already strictly monitored under existing legislation in France, in particular the Labor Code. Groupe BPCE’s human resources management policies provide a response to the challenges of achieving a fairer society, and address the transformation of its business activities over time. A series of voluntary charters, agreements and operational systems ensure the protection and safety of employees in performing their duties. “Activities” pillar EMPLOYEES

In addition, in France, BPCE is registered in the “AGORA” Lobbyist Register, in accordancewith the legal obligationsarising from Law No. 2016-1691 of December 9, 2016, Regarding Transparency, the Fight against Corruption,and Modernizationof EconomicLife, as well as the directivesof the High Authority for Transparency in Public Life (HATVP). In this context, BPCE reports its actions, commitments and expenses to the HATVP with the information required bylaw.https://www.hatvp.fr/fiche- organisation/?organisation=493455042 Lastly, at the European level, BPCE is also listed in the European Commission transparency register. As a reminder, this register is a database that lists organizations that attempt to influence the law-making and policy implementation process of the EU institutions. https://ec.europa.eu/transparencyregister/public/ consultation/displaylobbyist.do?id=179370613236-62

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DUE DILIGENCE OBLIGATIONS REGULATORY FRAMEWORK

Law No. 2017-399 of March 27, 2017 Duty of Care of Parent Companies and Ordering Companies applies to BPCE. This law requires the establishment and implementation of a vigilance plan aimed at identifying and preventing the risks of serious violations of human rights and fundamental freedoms, the health and safety of people, and the environment. The Group sees this new regulatory obligation as an opportunity to reiterate and continuously improve its existing due diligence plan.

Human rights and fundamental freedoms issues

Issues related to the health and safety of people

Environmental issues

The Group is committed to promoting compliance with a number of principles and standards that form the foundation of its activities, such as the United Nations Sustainable Development Goals (SDGs), the ten principles of the United Nations Global Compact, and the standards defined by the International Labor Organization (ILO). With regard to the monitoring system, existing risk assessment and control tools, the deployment and effectiveness of the actions carried out by group are monitored via KPIs formulated as part of the TEC2020 strategicplan or in the framework of its non-financial disclosures. They are summarized in tables (summary of the identified risk universe in the context of the DPEF/most relevant focus areas for Groupe BPCE/mitigation measures/monitoring indicators).

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE

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