GROUPAMA / 2018 Registration document

CORPORATE GOVERNANCE AND INTERNAL CONTROL RELATED-PARTY TRANSACTIONS

In 2016, each of them: appointed a person in charge of the key functionof “Compliance ❯ Verification”, whosename was reported to the ACPR; drafted its own Compliance policy on the basis of the Group ❯ Compliancepolicy by adapting it in keeping with the principle of proportionality; implemented the draftedCompliance policy. ❯ The Group Compliance Policy was revised in 2017 in the light of major regulatory developments at the European and national levels: the InsuranceDistributionDirective (IDD); ❯ the PRIIPs Regulation; ❯

the fourth Directive on the fight against money laundering and ❯ the financing ofterrorism; the EuropeanGeneral Data ProtectionRegulation(GDPR); ❯ the lawon the duty of duediligenceof parent companies; ❯ Sapin 2 law(on modernisation ofeconomic life). ❯ In 2018, details were providedon the ethics frameworkwithin each Group company based on the changes in the Internal Regulations to which the ethics charter and the code of conduct are now appended. The Policy also incorporates the roles and responsibilitiesof the Key ComplianceVerificationFunctionand the main players at the Group and corporate levels in the handling of ethics alerts.

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RELATED-PARTY TRANSACTIONS 3.5

Related-party transactions are presented in Note 44 on related-party transactions to the consolidated accounts for fiscal year 2018, audited by thestatutory auditors.

MAJOR CONTRACTS 3.6 Over the past two years, other than during the normal course of business, Groupama Assurances Mutuelles and its subsidiaries have not entered into any major agreementswith third parties that would confer a major obligation or commitment on the entire Group consisting of Groupama Assurances Mutuelles and its subsidiaries.

On the other hand, major agreementsbind GroupamaAssurances Mutuelles, its subsidiaries and the regional Groupama mutuals in the context of their business relations. These agreements are described insection 2 of Note 44of the consolidatedaccounts.

71 REGISTRATION DOCUMENT 2018 - GROUPAMA ASSURANCES MUTUELLES