GROUPAMA / 2019 Universal Registration Document

4 CORPORATE SOCIAL RESPONSIBILITY (CSR) Declaration of Extra-financial Performance

Groupama is the only insurer in France with a decentralised territorial structure, based in particular on local mutuals grouping together members and regional mutuals, which are autonomous, responsible, interdependent regional companies, particularly throughthe mechanismof reinsurance. The Group’s financial strength, illustrating the quality of managementand guaranteeingsustainability,was further bolstered in 2019: the Fitch agency raisedGroupama’srating again from “A-” to “A” (Strong) and maintainsa “Positive” outlook. Relationships of sharing between members, elected representatives, customers, and employees contribute to the differentiation and power of our model: the ability to combine operational and “emotional” knowledge allows Groupama to provide responses optimally tailored to needs, going beyond issuing policies. Governance and CSR strategy 4.2.1.5 The CSR team within the Internal Communication and CSR Department, attached to the Groupama Assurances Mutuelles Group HR Department,promotes and coordinatesthe CSR policy within the Group. It reports on the progress of the CSR strategy to the Group Ethics Committee,which includesthe Group’sexecutive managementand the CEOs of the regional mutuals. In particular, it leads a network of 50 correspondents/coordinators from all the Group’s entities (regional mutuals, Groupama Assurances Mutuelles, French and international subsidiaries, and the IT and logistics EIG Groupama Supports & Services), which participate in the developmentof action plans in their company and share their best practices. Led by the CSR team, the Group CSR Strategy is a master plan that defines areas for improvement in which the Group’s companies are active. The objective of this strategy is to mobilise the entire Group around CSR with high added value to serve the Group’s strategic challenges. The 2019-2021 plan was built through a collaborative approach, teaming up the CSR coordinatorsand managementof the companies in 2018, and for the first time with the employees (IMAGIN’RSE with 2,500 participants and more than 5,000 submitted ideas) and elected representativesthrough a CSR workshopduring a national training session. It was approved by the Group’s Ethics Committee on 17 April2019. It is structuredaround the 4 pillars of CSR, with revised phrasing in line with current CSR topics. Each pillar now consists of 3 commitments, fora total of12 commitments to progress: a caringemployercommittedto collectivesuccess; ●

an insurerthat develops solutionsand sustainableservices; ● a partner working in solidaritywith communitiesand regions; ● a responsible player in the ecologicaltransition. ● In 2019, employeeswere able to learn about the strategy in a fun, participatoryway by visitingthe AGI’RSEplatformmade availableto them for several weeks.

4.2.2

CSR ISSUES AND ASSOCIATED

RISKS

Risk assessment 4.2.2.1 In connectionwith order 2017-1180publishedon 19 July2017, the Group’s CSR risks were specifically mapped in order to prepare this declaration.This rating was done in view of the social, societal, and environmentalissues associatedwith our businessmodel.CSR risks are intended to complementthe current global management of the Group’srisks. The approach to the work, led by the CSR team with the assistance of the Group Risk Department, was as follows: first, classify and express “CSR” risks (for which there is currently no official normative list  (1) and simultaneouslyconstruct an evaluation grid (matrix) for these risks, based in particular on the COSO method  (2) . This list of risks and the assessmentmethodologywere then sent to the Business and Risk Departments of the Group’s entities for an initial rating, done as much as possible in gross terms  (3) . Lastly, the return of this rating made it possible to choose from among the CSR risks the “significant” risks presented in this document and validated in the meeting of the Group’s Ethics Committee on 11 December 2019. The assessment is based on an expert opinion after about twenty interviewsare conducted.The scope for this first exercise primarily concernedour main activitiesand business lines in France. The risk rating dependson the probabilityof occurrenceand the sum of the potential impacts (with an additional assessment factor, which is the incidentalready experiencedor not). In addition to this mappingwork, the following are indicated in this declaration: risks that are already incorporated into the Group Major Risks ● framework; risks or topics that must be reported according to the ● regulations.

Sources: the CSR reporting guide for the insurance sector produced by the FFA in 2018 as well as the 2015 practical guide of the ORSE (Observatory on (1) corporate social responsibility), of which Groupama is a member. Enterprise risk management to environmental, social and governance-related risks, COSO, October 2018. (2) In other words, intrinsic risk before risk control measures. (3)

73 Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES