BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

GUIDING PRINCIPLES These rules of conduct are illustrated with real-life situations that may be encountered by any stakeholder, including employees, managers, directors and other parties. When contradictory influences are at play, it is important that employees have clear rules to help them make the right decision.

The Code of conduct and internal policies and procedures provide clear instructions on how to behave, but they cannot provide a solution for all situations. Members of staff must exercise their judgment to make the right decision, drawing on the principles set out in the Code of conduct. If they have any doubts about what they are about to do, employees should ask themselves the following questions:

Is it legal?

No?

WHISTLEBLOWING

Yes Yes Yes Yes

Groupe BPCE employees can use the internal whistleblowing procedures in place in all Group entities to report

No?

Does it observe our policies and procedures?

breaches of the rules before they become serious risks.

Does it follow our culture, which puts the long-term interests of our customers and cooperative shareholders first?

No?

The Group protects whistleblowers. Under no circumstances may they be subject to any disciplinary action or legal proceeding, provided they have acted impartially and in good faith.

Would I feel comfortable explaining my decision to a third party (regulatory authority, the courts) or if I read about it in the media?

No?

Have I considered all the risks at stake for my entity or Groupe BPCE?

No?

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE

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