GROUPAMA / 2019 Universal Registration Document

7 FINANCIAL STATEMENTS Consolidated financial statements and notes

regulatory provisions. Groupama Assurances Mutuelles staff required to work on strategic transactions involving a listed company signan NDA foreach such transaction; in the fight against money laundering and terrorist financing ● (AML/CFT), the management is handled by the Group Compliance Division. Entities implement applicable regulatory provisionsand professionalguidancein those of their procedures relevant to this field. The key points of the procedure include categorisationof the risks of money launderingand the financing of terrorism,collectinginformationon customersand the sources of their funds on the basis of the size of the risk, an automated detection system for people on asset-freeze lists and politically-exposed persons, a CRM profiling system for life/savings business activities, and a permanent and periodic control mechanism to check procedures are followed properly. An anti-money laundering and combating the financing of terrorism organisational chart defines the roles and responsibilities of the various participants and stakeholders at Group level and at each operationalentity concerned,describes the mechanism in place with respect to informing and training employees, determines the methods and conditions for exchanging informationrequired for due diligence, and specifies the procedureto be followedfor control and risk monitoring.The Group ComplianceDepartment,in conjunctionwith a networkof AML/CFTmanagers in the insurancesubsidiariesboth in France and internationally,asset managementsubsidiaries,and regional mutuals, ensures that the Group complies with its obligations in this area; in applicationof the provisionsof the French data protectionand ● the General Data ProtectionRegulation (GDPR), the compliance systemrelies on the Data ProtectionOfficer (DPO) of the Group’s French entities declared to the French national data protection commission (“CNIL”) and on the network of internal data relay protection officers (DRPO): one officer per entity and nine for Groupama Assurances Mutuelles in areas implementing processes. This network changes based on the Group’s organisational modifications; with regard to the protection of medical data, Group ● recommendations are disseminated by the Groupama Assurances Mutuelles Business Division concerned or entity concerned. It is the responsibility of the various Group entities (regional mutuals and subsidiaries) to implement these recommendations,in partnershipwith the medical advisers, the Group Data ProtectionOfficer (DPO), and the Claims units of the Group Insuranceand ServicesDivision;

Application of insurance law and regulations governing the insurance business The Group Legal Department within the Corporate Secretary of GroupamaAssurancesMutuelles ensures, particularly on behalf of the Business Divisions of Groupama Assurances Mutuelles, the French insurance subsidiaries, as well as theregional mutuals: a function of monitoring and analysing legislation and case law ● and other standards (FFA professional standards, ACPR recommendations, opinion of the Rights Defender and the CCLRF, etc.) having an impact on the insurance business; (marketing, consumer protection, communication, advertising, development, subscription, execution, and termination of insurance products, etc.); the necessary anticipation and support to implement new ● regulationsfor this activity; information(notes, circulars, working groups, disseminationof a ● quarterlybulletinof legal informationin connectionwith customer protection); validation of new insurance policies developed by the Business ● Departments and other insurance subsidiaries of the Group as well asthe modifications made to existingpolicies; development and validation of distribution and partnership ● agreements in connection with insurance and other services; legal and tax advice (taxation applicable to products and advice ● in the areaof wealth managementsolutions); relations with the administrative authorities for control and ● support as part of these controls and any resulting consequenceson the insurancebusiness;buildingand runningof training and awareness raising sessions on the regulations applicable to the insurance business, intended for a variety of audiences (distribution networks, managers, etc.). 5.2.3 Specific procedures have been put in place to meet special requirements: To prevent insiderdealing,the policiesand proceduresgoverning ● the GroupamaAssurancesMutuellesBoardof Directorscontains a detailedreiterationof the statutoryand regulatoryprovisionson the various restrictionson persons privy to privileged information about listed companies and financial instruments traded on regulated markets. Groupama Assurances Mutuelles staff in charge of investing in financial instruments traded on regulated markets and those working in mergers-acquisitions sign a non-disclosureagreement reiterating these same statutory and 5.2.2 Other areas

253

Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES