BPCE - 2020 Universal Registration Document

FINANCIAL REPORT

CONTROLS OF ACCOUNTING AND FINANCIAL REPORTING QUALITY

the implementation of Covid-19 reports, requested by the • regulator through the FINREP reports, as well as by the supervisory authority (ECB) and which are the subject of a Pillar III publication under the annual and half-yearly financial statements; the continuation of the work that enabled the consolidation of • Oney; the implementation, for Groupe BPCE’s insurance entities, of • project structures in line with the changes brought about by IFRS 17 and the continuation of preparatory work for the applicationof this standard: examinationand documentationof normative choices, modeling, adaptation of systems and organizations, production of financial statements and changeover strategy, financial communication and change management; GENERAL SYSTEM The Group's internal control system contributes to the management of all types of risk and enhances the quality of accounting and financial information. It is organized in accordance with legal and regulatory requirements, including those arising from the Ministerial Order of November 3, 2014 on internal control and texts governing BPCE. It concerns all Group companies,which are monitored on a consolidated basis. The system is governed by an Umbrella Charter addressing the organization of Group internal control, which sets out the main principles, defines the scope of application, and lists all contributors along with their role, with the aim of ensuring that the internal control system of each company and the Group works effectively. This charter is supplementedby frameworks, including the framework on controls of accounting and financial information. DEPLOYMENT OF THE CONTROL SYSTEM FOR ACCOUNTING AND FINANCIAL DATA The Group has established and implemented a system for verifying the quality of accounting and financial information in accordance with the requirements of the Ministerial Order of November 3, 2014 on internal control, and particularly Article 11c), which requires the “verification of accounting and financial reporting quality, related to information addressed to either the executivemanagers or the supervisory body, whether submitted to the supervisory and control authorities or appearing in documents intended for publication.” This system is implemented by various participants at three levels, ensuring a strict separation between the different lines of defense: level one controls are performed by all persons involved in the • production and publication of accounting and financial information (controls of accounting information are coordinated by the Accounting division); level two controls are carried out by a specialized function (the • Financial Control function), working with other level two control participants, as applicable; level three controls are primarily conducted by the Statutory • Auditors as part of their regulatory audit assignments (financial audit). The Group Secretary General ensures, with the support of a functional Financial Control unit led by the Group Financial

the adaptation of Groupe BPCE’s systems to enable the • implementation of the systems put in place in the context of the Covid-19 crisis, in particular the State-guaranteed loans (SGL) and the moratoriums granted to its customers; the finalization of the implementation of the target IS • architecture (Normalized Exchange Zone (ZEN)) in compliance with the IT Master Plan to ensure the consistency of the common data used in the main central and local reports; the implementation of a transversal project focused on • Finance and Risk data, intended to finalize the operational implementation of BCBS 239 requirements and integrate these requirements into the daily life of the business lines.

Accounting and financial data control process 5.8.3

Control department, the implementation of this system based on the rules and principles that it has defined around three standards: the framework for quality control of accounting and financial • information, updated and validated by the Group Internal Control Coordination Committee on June 17, 2020. This Framework defines the rules and principles of controls and responsibilities relating, on the one hand, to the production and publication of information sent “to the supervisory and control authorities or included in the documents intended to be published” (so-called regulatory reports: accounting, tax or regulatory) and on the other hand on the reports intended for the effective management or the supervisory body (management or internal deferrals); the Framework for the preparation and publication of reports • and management indicators approved by the Standards and Methods, Risks, Compliance and Permanent Control Committee on December 12, 2018. This Framework defines the rules and principles relating to the information transmitted to the effective management or the supervisory body (so-called steering or internal reports) and provides operational details to ensure the implementation of regulatory requirements relating to reports (in particular those defined by the Order of November 3, 2014 on internal control and BCBS requirements 239); the Framework for Statutory Auditor Assignments at Groupe • BPCE, approved by the BPCE Supervisory Board on November 7, 2017, which sets out the rules and principles governing statutory audits in the Group. AT INDIVIDUAL INSTITUTIONS Internal control procedures are decentralizedby nature owing to the Group’s unique organizational structure and are adapted to the particular requirements of each consolidated entity, in compliance with the general rules and principles set by the Group.

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AT THE CENTRAL INSTITUTION Level one controls

In addition to the level one self-checkingand control procedures performed in the entities responsible for preparing individual or consolidated financial statements, the quality of accounting and financial controls is also verified by the Accounting division, which oversees the production of accounting and financial information.

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE