BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

In its financing activities, for several years now, Groupe BPCE, including Natixis, has addressed the human rights and environmental risks incurred by some of its financing activities, most notably by applying the Equator Principles for project financing and specific policies for sensitive sectors. (See Chapter 2.2.1, “Our commitments” and Chapter 2.3.1, “Integrating the fight against climate change and the protection of biodiversity in our development strategy.”). As a signatory of the Equator Principles, for the past several years, Natixis has applied a system for measuring and managing risks related to human rights and the environment in its project financing activities. For the most sensitive sectors, CSR policies have been introduced and integrated into the risk policies of the business lines working in the sectors concerned. These policies at Natixis cover the following sectors: coal, defense, tobacco, and oil and gas industries. The nuclear, mining & metals, and palm oil sectors are covered by policies for internal use. In addition to these procedures, Natixis has developed an internal screening tool, called the ESR Screening Tool, for the assessment of Environmental, Social and Governance (ESG) risks.

The ESR Screening Tool, a mandatory system, systematizes the analysis of ESG risks for new customers and the granting of credit for corporate clients of the Large Bank, where a level of due diligence is assigned according to four criteria (ESG controversies of which the client is a subject/geographies and activities in which the client operates/maturity of its ESG risk management system/businessrelationshipwith Natixis.). It aims in particular to comply with the new obligations introduced by the French due diligence act (see Ch and ap. 2.3.1 – Integrating the fight against climate change and the preservation of biodiversity into our development strategy.). Procurement pillar In a concerted approach, BPCE Procurement, acting on behalf of Groupe BPCE, and three other banking groups decided to map out their CSR risks by procurement category using shared classifications covering around a hundred sourcing categories. The CSR risk map and the corresponding due diligence plan were presented to the Procurement and CSR functions in 2018. The map identifies risks of serious violations and prioritizes the necessary actions in each category. It also incorporates the risk associated with the country in which the majority of the added value on each product and service is generated.

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Mapping identifying 13 categories of purchases with high or very high risks regardless of country risk, which can minimize or maximize intrinsic risk

Indicators are used to monitor the rollout of the due diligence process for high and very high risk procurement categories: At the end of 2020, 62% of relevant procurement categories had been assessed. These are the following categories of purchases: servers • ATMs • bank cards • relationship marketing • furniture • long-term vehicle leasing • acquisition vehicles • vehicle taxes • 100% of BPCE Procurement buyers responsible for these procurement categories have received training.

Framework of the consultations managed by BPCE Achats on behalf of the Groupe BPCE companies

For these categories, a specific system has been put in place. Under this procedure, suppliers must complete a questionnaire specific to each category and provide details of the action taken to mitigate the risks and prevent major violations. BPCE Procurement assesses these actions and assigns a CSR rating, which is included in the supplier’s overall rating. Depending on the results, an improvement plan is established with the chosen suppliers, subject to review at the six-month point. This system can be implemented for suppliers already listed or generating significant revenue with Groupe BPCE.

System outside the framework of the consultations managed by BPCE Achats on behalf of the Groupe BPCE companies

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 achieved most of the objectives set: number of Group companies awarded the Supplier Relations • and Responsible Purchasing label increased to 14 companies as planned, i.e. double compared to the start of the expired strategic plan; improvement of supplier payment terms (30 days), • establishment of a multidisciplinary working group to identify and implement best practices; made progress in integrating CSR into its procurement • actions. 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.

Whistleblowing Groupe BPCE has a whistleblowing system in place setting out the applicable procedure at all Group entities, as provided for in the Act of December 9, 2016 (Sapin 2 Act) and the Ministerial Order of November 3, 2014 on internal control of banking sector companies. The current whistleblowing procedure applies to all internal employees, as well as to external and occasional staff, who may use the procedure should they become aware of any crime, offence, major violation of the law, threat or major breach of general interest or any conduct or situation that breaches the code of conduct. Groupe BPCE entities protect whistleblowers. Under no circumstancesmay they be subject to any disciplinary action or legal proceeding, provided they have acted impartially and in good faith. The entire system,which also takes into account the duty of care, is available on the Group’s website: https://groupebpce.com/le- groupe/ethique-et-conformite. The system is expected to see further developmentsas part of the transpositionof directive(EU) 2019/1937.

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE