GROUPAMA / 2019 Universal Registration Document

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

In 2018, the CNIL issued 28 “PersonalData Governance”labels to the Group’s French companies having shown that they were prepared for the implementationof the GDPR. It is a mark of strong trust for ourmembers, customers, employees, and partners. Some examplesof the control measures: deployment of the ethics framework (ethics charter, Code of ● Conduct,ethics whistleblowingsystem): available in the event of personalhealth and safetyviolationsin particular; general deployment of a cyber risk information campaign, ● including e-learning training for all employees; likewise for training in GDPR requirements (e-learning); ● compliancewith the GDPR requirementsfrom the perspectiveof ● both data processing(with regard to customersand in relationto third companiespotentiallyworking on the data) and processes (DPO, procedure, etc.). The mostappropriateperformance indicator is being defined. Regardingthe other issues and associatedrisks (indirect impact of policies, responsible purchasing, socially responsible investments)  (1) : In addition to data protection risk, the risk of indirect physical impact or human rights violations due to our insurance policies is immaterial. The issue of responsible purchasing (e) The Group is a producer of services, using commercial buildings. Purchases are made mainly in four areas: IT and telecommunications,intellectual services (strategy consulting, HR consulting, training, marketing, travel, etc.), general resources (building management as a whole: construction, occupant services, etc.), and insurance purchases. In applicationof the Ten Principles of the UN Global Compact and the charter on diversity, CSR commitments have been integrated into the Group’s purchasing policy, including a purchasing ethics charter, which has been incorporated into the internal bylaws of Groupama Assurances Mutuelles. 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’scompliancewith the labour law and the rulesof the ILO. There is a written policy on subcontracting and outsourcing importantand critical activities. Groupama has signed the inter-company charter (which became the responsible supplier relations charter  (2) , which particularly favours long-term relationships with SMEs, incorporation of CSR criteria into the selection of suppliers, and consideration of the territorialresponsibility of a large group.

In addition, in our calls for tenders, we ask our suppliers, in connectionwith the supplier CSR charter that we have developed or specific contractualclauses, to declarewhether they respect the principles of the ILO, the Universal Declaration of Human Rights and the charter of the Global Compact(workingconditions,respect for the environment, ethics), and we encourage them to adopt eco-responsible behaviour (product design, staff training, and transport and management of waste). A “CSR” clause is inserted into the contracts. Examplesof actions that illustrate the managementof this issue by the Group includeGDPR-specifictraining forbuyers and employees (100% of buyers in the Purchasing Department of Groupama Supports & Services trained and 100% of the regional mutuals trained in 2019). GroupamaSupports& Serviceshas a supplierrisk monitoring tool (e-attestation),which allows for the surveillance of all suppliers with which contracts have been entered into. In addition to the three obligations (K-bis, payment of social contributions, and list of employees subject to a declaration of work), the tool makes it possible to monitor their insurance, the certificationsspecific to each business line, etc. Deploymentof this tool in the regionalmutuals isplanned bymid-2021. The issue of implementing the Sapin 2 law – (f) combating corruption and influence peddling Addressed in 4.2.2.6. The issue of socially responsible investments, (g) namely consideration of the social/societal impact of companies in which Groupama invests This issue has been defined and controlled for many years at Groupama, and the work to make these analyses more thorough continues. For more than 20 years, Groupama, a financial player in the economy’slong-termdevelopment,has been involved in promoting Socially Responsible Investing (SRI) through its third-party asset management subsidiary, Groupama Asset Management. Its expertise in analysis and research, its management products and its mobilisationwithin many French and internationalrepresentative environmentsmake it one of the recognised leaders in this field. In addition to rolling out this specific SRI strategy, Groupama Asset Management has established a global objective of ensuring the widespread integration of ESG (Environment, Social, Governance) criteria into all management operations  (3) . To affirm this commitment, Groupama Asset Management established an ESG Strategy Department in 2018 to accelerate the integration of ESG into all portfolios.

Regarding the issue of societal commitments to sustainable development, see part 4.2.2.5. (1) Designed in 2010 by the Médiation des entreprises and the Conseil National des Achats. (2)

The policy of integration of ESG criteria by Groupama Asset Management into the financial management of the Group’s assets is gradually applied to the (3) universe of European medium/long-term assets (government and credit bonds and equities). At first, this integration was implemented for the management of Euro/Europe equities only within open or dedicated mutual funds managed by Groupama Asset Management, held by the Groupama group’s entities and/or disseminated to outside customers. Starting in 2010, this integration was gradually extended to the management of credit bonds (companies) and European sovereign debts (States). The scope of assets incorporating an ESG approach (Responsible Investment assets) thus involves all securities and money market funds held directly or indirectly.

79 Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES