GROUPAMA / 2019 Universal Registration Document

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

Fight against corruption, influence 4.2.2.6 peddling, money laundering, terrorist financing, and tax evasion At the Group level, the global implementation of anti-corruption measures as well as measures against money laundering and terrorist financing(AML/CFT)is managedby the GroupCompliance Department with the assistance of the Group Legal Department and theGroup HR Department. The “Sapin 2” law of 9 December2016 on transparency,the fight against corruption, and modernisationof the economy came into force on 1 June 2017. It establishes a general obligation of prevention (before criminal offences are committed) against corruptionrisks for companieswith more than 500 employeesand their subsidiaries located in France or abroad. This obligation requires the operational implementation of eight specific measures. Groupamahas a Code of Conductappendedto the internal bylaws and hasdeployed an ethicswhistleblowing system. Upon completion of the approval process by the staff representativebodies, all employeeswere informedof the elements appended to the internal bylaws, namely regarding the following measures: the ethics charter, which reflects the essence of the values and ● commitmentsadoptedby the Group; the Code of Conduct lists the rules for all employees in their ● activities as well as the ethics whistleblowing system and the corresponding disciplinary measures for violatingthese rules; the ethics whistleblowingsystem in place (with each companyof ● the Group), which concerns the right of all collaborators (employees, officers, or general agents as well as external and occasional collaborators) to use a dedicated secure email address to report information about the following areas to the authorised persons of their company (the head of the ComplianceVerification Function or the Compliance Officer): corruption, influence peddling, ● violationsof humanrights and fundamental freedoms, ● harm tothe environment, ● internal fraud, ● crimes or offences, ● threat or severeharm to the public interest. ● The ethics charter and the Code of Conduct apply to all Group companies, bothFrench and international. In 2019, the Group incorporated modules specifically aimed at combating corruption and influence peddling for all its employees, including those most at risk (specialised modules according to activities), into its trainingprogramme. The steering and monitoringof this work will continue in 2020 and 2021.

The mutualist territorial network is led in particular by the local network consisting of elected representatives, who interact with policyholders and players in the territories. The Group promotes this mutual insurance dynamic by developing training for elected representatives,especially in territorial intelligence, by encouraging them to share good practices with each other, and by optimising discussions with employees, in particular those responsible for promoting mutual insurance principles and commercial development. Some figures… ● €46.2 million was paid to local authorities in the form of the territorial economicdistribution(CET) in 2018 (the amount for 2019 will be known in spring 2020). €11 billion in benefits were paid in 2019  (1) to our policyholdersto allow them toprotect their economic activity and their family life. For employment, the Group and its companies represent 25,000 employeesthroughout France, and recruitment events are organised each year (in13 major cities in both2018 and 2019). After the issuance of first mutual certificates in 2015 by a regional mutual, similar operations followed for the other eight metropolitan mutuals. In particular, they strengthen the investment capacity of the mutuals in the regions. Mutual certificates totalled €601 million overall, including €60 million collected in 2019. The regional mutuals are reinsured by the national mutual, Groupama Assurances Mutuelles. Significant territorialphilanthropy… ● In addition to the impacts of our economic activity – through local employment, payment of benefits, tax contributions, etc. – the Group conductsmultipleactionsto supporteconomicinitiative in all its forms, academic partnerships, solidarity actions, and philanthropy.Almost all of the Group’s companies thus engage in local societal actions/partnerships. Companies favour certain themes. Examples include entrepreneurship, disability initiatives, solidarity, culture and heritage, the environment, cinema, and prevention. In 2019, a significant philanthropy initiative was developedon cyclingin the territories. The amount of societalphilanthropy in 2019 was €7 million, including €1.1 million for the fight againstrare diseases(research, ● support for associations, medical information, with the Groupama Foundation and the regional mutuals). The “Balades solidaires” (Solidarity Walks) and events organised in 2019 also raised €350,000; including €560,000 in support for cinema (support for young ● creators and distributionas well as the Cinémathèquefrançaise with theGan Foundation). The website groupama.fr launched the section www.lavraievie. groupama.fr as a true external showcase of the actions in the territoriesconcretelypromotingmutual insurance.

The exact figure is €10.993 billion, including €9.3 billion in France, combined scope (France and International), excluding claims management costs. (1)

83 Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES

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