BPCE - 2020 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT

BEING A RESPONSIBLE GROUP IN ITS INTERNAL AND EXTERNAL PRACTICES

A dedicated e-learning training course to ensure that everyone is familiar with the principles of the Code has been developed and put online since the first quarter of 2019. This training was made mandatory for all Group employees and for all new hires within 12 months of their arrival. Thus, at the end of December 2020, nearly 92.7% of registered employees, including those of Natixis, had followed the training. Another training course entitled “The Essentials of Ethics” completes the system; composed of skits illustrating specific cases of behavior to be prohibited, it was supplemented by three additional skits in 2020, bringing the total to 15. Since the end of 2019, a “code of conduct” dashboard, covering the Group’s scope, lists 36 indicators collected from all Group entities, and is presented twice a year to the Supervisory Board’s Cooperative and CSR Committee (third edition, presented at the end of 2020). It collects data and information on the deployment of the system, incidents, disciplinary sanctions and types of breaches. PREVENTION OF CORRUPTION Groupe BPCE condemns corruption in all its forms (active, passive, influence peddling, facilitation payments) and in all circumstances. It is a signatory of the United Nations Global Compact, whose tenth principle states that “Businesses should work against corruption in all its forms, including extortion and bribery.” ANTI-CORRUPTION MEASURES The Group’s employeesare required to comply with the internal rules and procedures that help to prevent and detect behaviors likely to characterize acts of corruption or influence peddling. These rules and procedures are intended to identify risky situations and constitute a system that aims to comply with the requirementsintroducedby Article 17 of the Act of December 9, 2016 on transparency, the prevention of corruption, and the modernization of the economy (“Sapin 2”). The prevention of corruption is part of the financial security mechanisms of the Group’s activities, notably through: taking measures against money laundering, corruption • (monitoring the transactions of “politically-exposedpersons,” considering countries at risk), and fraud; ensuring that employees observe the Code of conduct and • professional rules of compliance and ethics by applying policies governing conflicts of interest, exchanges of gifts, benefits and invitations, confidentiality, and professional secrecy. Disciplinary sanctions have been defined for any failure to respect professional rules governing the activities conducted by Group companies; exercising due diligencewhen making contributions to political • campaignsor to government agents, donations, patronage and sponsorship, or lobbying; supervising relations with intermediaries and business • introducers via groupwide standardized contracts describing the reciprocal services and obligations, and committees for approving and contractually establishing compensation terms; a mapping of exposure to the risks of corruption in the • activities of the Group entities, the methodology of which is being overhauled in order to improve its effectiveness;

an entry-level policy with suppliers, based on a mapping of the • exposure of purchasing categories to the risk of corruption, and rules for assessing suppliers, which are common to the Group’s entities. This policy and the associated KYS system are implemented by BPCE Achats for Tier 1 suppliers (purchases over €50,000); regulatory training on professional ethics and the fight against • corruption in the form of e-learning, mandatory for all new employees and, in 2021, for all staff. This training was enriched in 2020 to present concrete examples of behaviors likely to constitute acts of corruption; a system for collecting professional alerts is included in the • internal regulations. Employees and external service providers have a procedure in place for implementing the whistleblowing system. The Group also has a comprehensive corpus of standards and procedures setting out the rules governing the strict separation of operating and control functions, including: a tiered system of delegation of authority for granting loans; • standards and procedures governing KYC and due diligence • procedures used for customer classification and supervision purposes. In the interest of organizing the internal control system, whistleblowing/detection tools and permanent control plans serve to bolster the security of this system. In 2021, the elements of this system will be explicitly flagged towards the risks of corruption identified by the business lines in the new risk mapping. BPCE also has accounting policies and procedures in place in line with professional standards. The Group’s internal control system for accounting information is based on a structured audit process to check the conditions in which such information is assessed, recorded, stored and made available, in particular by verifying the existence of the audit trail. This control system is part of the fraud, corruption and influence-peddling prevention and detection plan. In 2020, a Group repository of dedicated controls was formalized. From a more general standpoint, these systems are formalized and detailed in the Umbrella Charter governing the organization of Group internal control and the Risk, Compliance and Permanent Control Charter. These charters apply to parent company affiliates and all BPCE subsidiaries. FIGHTING AGAINST MONEY LAUNDERING AND PREVENTING FRAUD Financial security covers anti-money laundering and terrorist financing (AML-TF) measures as well as adherence to international sanctions aimed at individual persons, entities or countries. Groupe BPCE works to prevent money laundering and terrorist financing through: CORPORATE CULTURE Promoted across all levels of the company, corporate culture is built on: customer relations principles aimed at preventing risks, which • are formalized and regularly communicated to the employees;

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UNIVERSAL REGISTRATION DOCUMENT 2020 | GROUPE BPCE