BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

CSR REPORTING METHODOLOGY

Various initiatives were taken in this respect in 2020, in collaboration with all of the contributors to the non-financial performance report, to facilitate the appropriation of this new process by all Group entities: groupwide distribution of a memorandum going over • regulations and detailing the reporting process for the business lines; organization of two days of seminars for the CSR function: • a one-day presentation of the tool box used to implement – the non-financial performance report in their entities and the methodology, attended by the four independent third parties working with the Group, a one-day conference for all CSR officers from every entity – to inform them about the importance of CSR reporting and answer their questions about the data collection process; awareness-raising among the Group’s business functions • about CSR reporting issues through visits by the sustainable development team (the credit exposure managers club, real estate & logistics conference, national procurement meeting, etc.); two carbon review training sessions (beginners and advanced • levels), a CSR reporting training session and two sessions on the basics of CSR; two conference calls attended by nearly all of the sustainable • development officers to provide advice and answer questions about the non-financial performance report and the collection of CSR data. REPORTING TOPICS The following topics are considered relevant in terms of the bank’s indirect impacts: circular economy, reducing food waste, combating food poverty, improving animal welfare and ensuring responsible, fair, sustainable food supplies. These topic are not addressed in specific paragraphs in this report but are covered by the bank’s ESG risk analysis procedures. For its lending business, these topics are covered in sector policies. For investment and asset management activities, they are covered by the ESG ratings methodologies for fund management. The matrix used to rate the 21 non-financial risks provides a rating system for gross risks based on their frequency and severity over a three-year period. It also measures the Group’s net risk exposure in terms of the risk management systems (processes/quality, resources, controls) used. User Guides The user guide, addressed to all contributors to the Group CSR reporting processes, was updated for 2020. With respect to the universal registration document (but also for each entity, i.e. annual management report or URD), it defines the following: the regulatory environment; • the timeline; • the reporting process (scope, rules on extrapolation for • incomplete data, consolidation rules and the information control process); a glossary. • ROLE OF METHODOLOGY TOOLS Risk analysis matrix

This guide also relies on a CSR reporting standard that specifies all of the indicators published, their definitions, their units, the corresponding GRI reference, their sources, how they are calculated and collected, and examples of controls to carry out. The Group carbon-reviewuser guide was also updated in 2020. The guide is intended to promote the carbon-review system. The purpose of this guide is to: present the general principles of the method developed by the • Group; review the system’s history and the most recent changes to • the system; offer a uniform presentation of the reporting rules for Groupe • BPCE’s greenhouse gas emissions reviews (reporting period, scope, extrapolation rules, etc.); enable departments to establish action plans for carbon • reduction while meeting the requirements of Article 75 of the Grenelle 2 Act, which concerns greenhouse gas emissions reviews and the Local Climate-Energy Plan (“PCET”) plan. In 2019, the Group published three methodology memos for Travel, Fixed Assets and Procurement. Reporting period Published data cover the period from January 1, 2020 to December 31, 2020. Where physical data are not comprehensive for the period, contributors make approximate calculations to estimate the value of the missing data from average ratios provided by Groupe BPCE (in the user guides) based on FTEs and/or the surface area covered. The contributors review the estimates used and send their comments along with the information provided and approved by the Group. Comparability For 2019, Groupe BPCE chose only to report figures for a single year for some indicators, namely those that have undergone a major change in definition since 2019 and some that were newly introduced in 2020. Controls The “ESG information quality control framework” defines the organization of control systems for ESG information within Groupe BPCE, and describes the main policies in place on this subject. It applies to all Groupe BPCE entities in the consolidated scope: the central institution, its direct and indirect subsidiaries, all BPCE affiliates and their subsidiaries. Each entity is responsible for the accuracy of its CSR data. The same applies to Groupe BPCE’s operational divisions. At Group level, all data collected are verified and subject to a careful review of units and data consistency. Contributors are asked for an explanation where figures appear unjustified. The third level of control is the Internal Audit, which performs checks on entities’ CSR reporting as part of its multi-annual audit plan (since 2017). If any data published in the management report for the previous year prove inaccurate, a correction is made with an accompanying explanation on the bottom of the same page.

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE

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