GROUPAMA / 2019 Universal Registration Document

8 LEGAL INFORMATION Company information

WHO MAY BE CONSIDERED AN “INSIDER”? Members of the Board of Directors,the Chief ExecutiveOfficer and any personhaving inside information in the course of his/her duties. WHICH FINANCIAL INSTRUMENTS ARE CONCERNED? In particular, they include any financial instrument traded on a regulated market or on a multilateral trading facility (MTF) or an organised trading facility (OTF): shares or other rights that grant or may grant access, directly or indirectly, to share capital or voting rights, debtsecurities,mutual fund sharesor units, or derivatives. WHAT IS “INSIDE INFORMATION”? This is specific information that has not been made public, which involves, directly or indirectly, one or more issuers of financial instruments or one or more financial instruments and which, if it were made public, would be likely to have considerable influence on the prices of the financial instruments in question or the derivatives tied to them. Information is considered to be specific if it mentions a set of circumstancesthat exists or is reasonablylikely to exist or an event that has happened or is reasonably likely to happen, when it is possible to conclude from the information the effect that those circumstances or that event could have on the prices of the financial instrumentsconcerned. Informationthat, were it to be made public, would be likely to have considerable influence on the price of the financial instruments concerned is information that could be used by reasonable investors as one of the foundations of their investment decisions (buy, sell or hold). WHAT INFORMATION OR EVENTS RELATING TO AN ISSUER OF FINANCIAL INSTRUMENTS MAY BE CONSIDERED AS CONSTITUTING INSIDE INFORMATION? Examplesinclude: earnings (or estimated earnings), and changes thereto that are ● higher or lower thanannounced forecasts; mergers, acquisitions, public offerings, joint ventures, disposals ● or changes in assets, acquisitions of interest, majorpartnerships; major new productsor changes involvingcustomersor suppliers ● (such as the acquisition or loss of a customer or a major contract); major litigation, investigationsor proceedingsconducted by the ● audit authorities; a one-time event linked to the business, which may have a ● significant effecton earnings; events affecting the financial instrumentsof the issuer (failure to ● repay debt, early redemption,buyback programmes,division of par value or shares, modificationsof dividends, changes to the rights of holders of financial instruments,public or privatesales of additional financial instruments). This list is not exhaustive;other informationmay be consideredas privileged dependingon the circumstances.

WHEN MAY INFORMATION BE CONSIDERED AS NOT PUBLIC? Information is not public when it has not been disclosed through, for example: an official press release, news service or mass-circulationdaily ● newspaper; an official document filed with a control authority (such as the ● registrationdocument filed with theAMF); the Internet; ● documents sent to shareholders (annual report or information ● prospectus). Applicable rules Membersof the Board of Directors,the Chief ExecutiveOfficer and persons attending Board meetings may receive inside information about issuers of financial instruments admitted to a regulated market or other trading facility, for example,during the examination of a partnership, merger/acquisition or equity investment transaction. Issuers in which the Group holds a strategic investment are especially concerned. CONFIDENTIALITY Any member of the Board of Directors, the Chief ExecutiveOfficer and any person attending meetings of the Board of Directors holding, in the courseof his or her duties, inside informationrelating to an issuer of the aforementioned financial instruments or to financial instruments of such an issuer is bound by a duty of confidentiality with respect to such information. They are forbidden to disclose this information outside the normal frameworkof their functionsor for reasons other than those related to why the informationwas disclosedto them. If the person in question must divulge this information to other persons in the Group or third parties for the purpose of exercising their functions, he/she undertakes to do so only after having informed such persons or third parties that the information is confidential and that they are required to comply with the rules applicable topersonswho have inside information. TRADING IN FINANCIAL INSTRUMENTS As long as the inside informationhas not beenmade lawfullypublic, the member of the Board of Directors, the Chief Executive Officer and any person attending meetings of the Board of Directors holding inside information in the course of his/her duties about an issuer of financial instrumentsor a financial instrumentadmittedto a regulated marketor a trading facilitymay not: use the inside informationthat he/she has, acquireor disposeof, ● or attempt to acquire or dispose of, on either his/her own behalf or on behalf of others, directly or indirectly, the financial instruments tied to that information or any financial instruments to which thoseinstrumentsare tied;

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Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES