GROUPAMA / 2018 Registration document

CORPORATE SOCIAL RESPONSIBILITY (CSR) GROUPAMA’S 2018 EXTRA-FINANCIAL PERFORMANCE REVIEW

The new system is now as follows: the ethics charter reflects the essence of the values and ❯ commitments adopted by the Group; the code of conduct lists the rules for all employees in their ❯ activities aswell as the ethics alert system; the ethics alert system in place (with each company of the ❯ Group) concerns the right of all collaborators (employees, officers, or multi-line agents as well as external and occasional collaborators) to use a dedicated email address to report information about the following areas to the authorised persons of their company (the head of the Compliance Verification Function orthe Compliance Officer): corruption, influencepeddling, ■ violations of humanrights andfundamental freedoms, ■ harm to the environment, ■ internal fraud, ■ crimes oroffences, ■ threat or severe harmto the public interest. ■ The ethics charter and the code of conduct, appended to the Internal Regulations, are legally binding documents. They apply to all companies of theGroup, both in France and internationally. This ethics systemset up in the Groupmeets the obligationsof the Sapin 2 law and the law on the duty of vigilance of parent and instructing companies. In applicationof The Ten Principlesof the UN Global Compact and the diversity charter, CSR commitmentshave been integrated into the Group’s purchasing policy, including a purchasing ethics charter, which has been incorporated into the Internal Regulations of Groupama AssurancesMutuelles. It discusses three aspects in particular: consideration of methods of manufacture of materials, the behaviour of suppliers in respect of these methods of manufacture, and the supplier’s compliance with the labour law and the rules of theILO. Groupama has signed the inter-company charter, which particularly favours long-term relationships with SMEs, incorporation of CSR criteria in the choice of suppliers and consideration ofthe territorialresponsibility ofa large group. In addition, in our calls for tenders, we ask our suppliers,as part of the Supplier CSR charter specific contractual clauses, to declare whether they respect the principles of the ILO, the Universal Declaration of Human Rights and the charter of the Global Compact (working conditions,respect for the environment,ethics), and we encourage them to adopt eco-responsible behaviour (product design, staff training, routing, waste management). A “CSR” clause is inserted into the contracts. CSR commitments in relations 4.2.3.3 with subcontractors and suppliers

Purchasesmade by the Group relatemainly to fourareas: IT and telecommunications; ❯ intellectual services (strategy consulting, HR consulting, training, ❯ marketing,travel, etc.); general resources (management of the building overall: ❯ construction,service for occupants, etc.); insurance purchases. ❯ Compliance 4.2.3.4 Groupama has a group compliancepolicy, validated by the Board of Directors of Groupama SA (now Groupama Assurances Mutuelles), in order to ensure that the practices of the Group’s componentsare consistentwith all laws and regulationsas well as the standards enacted by the supervisory authorities and professional practices. It presents the organisation implemented to achieve this objective and the organising framework of the system for managing risks of non-compliance, i.e. : the arrangements put in place in agreement with the Group’s ❯ strategy andin keeping withits risk appetite; the roles and responsibilities of key players at the Group and ❯ company levels. The Group Compliance policy applies to all companies of the Groupamagroupboth in Franceand abroad,respectingthe rules of proportionality(nature of activities and associated risk policy, size, workforce, etc.) as provided for in Directive 2009/138/EC, regardless of whether they are subject to Solvency 2 or to any equivalent legislation/regulation.This policy also takes into account the provisions of the Insurance DistributionDirective (IDD) and the Sapin 2 and Duty of Care laws. The measures to implementthese laws are mentioned in the Risk Management section of the registrationdocument. The “ComplianceVerification”function is independentof operational activitiesand reportsdirectlyto a memberof the SteeringCommittee who does not carry out any operationalfunctionwithin the entity to whichhe or she belongs.The functionmeetsthe criteriaof skills and good characterand is the subjectof a notificationto the ACPR.The function is subject to a duty to alert the governancebodies of the Group and the Group’s companies as well as to the supervisory authorities. With the understandingthat non-compliancerisk is a cross-group operationalrisk, and the non-compliancerisk control system is one of the essential componentsof internal control organisedwithin the Group. Compliance essentially covers the themes pertaining to the Group’s core business, i.e. , non-life insurance, life insurance,asset management, and real estate governed particularly by the insurance, monetary and financial, consumer, and commercial codes, the General Regulation of the AMF, as well as the regulations from the supervisory authorities to which these activities are subject. More specifically, it covers: the protectionof customers; ❯ the fight against money laundering and terrorist financing; ❯

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REGISTRATION DOCUMENT 2018 - GROUPAMA ASSURANCES MUTUELLES