GROUPAMA / 2019 Universal Registration Document

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

4.2.3

ADAPTING TO CLIMATE CHANGE: THE GROUP’S ECOLOGICAL FOOTPRINT

The fight againstmoney launderingand terroristfinancing is also an important issue for the Group’s companies subject to such regulations. The system is managed by the Group through a network of designatedAML/CFTmanagers in allthese entities. An AML/CFT organisational chart defines the roles and responsibilitiesof the various participants and stakeholders at the level of the Groupand each operationalentity concerned,describes the mechanism in place with respect to informing and training employees exposed to these risks, and defines the methods and conditions forexchanges ofinformation required for due diligence. The Group Legal Department ensures dedicated legal and regulatory monitoring as well as interpretation of standards/sanctions. The Compliance Department is responsible for managing the Group’sAML/CFT framework. In this context,its role is to: define the AML/CFT risk management policy; ● ensure the operational deployment of procedures and ● corresponding tools; devise the permanent control plan and verify its implementation ● in orderto havea centralised viewof riskmanagement. To this end, the ComplianceDepartmentmanages the network of the abovemanagers. Reports are regularly made to the Senior Management of Groupama Assurances Mutuelles and to the Group’s governance bodies. Performance indicator ● Corruption prevention training. Number of employees trained in ethics and anti-corruptionthroughe-learning:15,023,or 67.85%of the workforce. AML/CFT training. Number of people trained (employee awareness): 4,663-training coursescompleted in 2019. These training courseswere implemented starting in early 2019. Lastly, with regard to taxes, Groupama Gan Vie, the Group’s life insurance subsidiary,does not engage in businesswith customers who are not French taxpayers in the course of its business activities. However, the Company’s distribution processes have provided for, through its sales support tools deployed in the distributionnetworks,the identificationof tax-delinquentcustomers in orderto comply withthe FATCAand CRS  (1) regulations.

This is a CSR topic imposed on all players. In connectionwith its CSR strategy, the Group is committed to reducing its CO 2 emissions and fighting climate change, both through its organisationand by encouragingthe eco-friendlybehaviours of its stakeholders(includingemployees  (2) . The Group has voluntarilyset a goal of reducing carbon emissions from its operations by 15% between2013 and 2021. In its organisation, the levers pertain to energy consumption, business travel (including the fleet purchasing policy), and paper consumption. The Group’s CSR team drives this objective by sharing information,by promoting community actions, in particular by sharing good practices ( e.g. regardingmobility, decarbonisation initiatives, etc.), and in liaison with the Logistics WG led by Groupama Supports& Services and including the regional mutuals. Given that our business is in the service field, the direct impacts of the Group’s companies on the environment are limited: our businesses do not constitute threats to biodiversity, water, or soil use. In terms of environmentalprotection, our employees are regularly informed of environmental issues, in particular through the European Sustainable Development Week, and communication/awareness efforts continue in the Group’s companies through various actions: educational information, CSR workshops, green team building, challenges, eco-driving awareness campaigns, and the establishment of carpooling in certain entities. The Group’s companies have set up hives and urban gardens, and some are promoting direct distribution with sales from local producers (Granvillage) on their sites. The development of pull printing – badge recognition at printers – allows for more reasonable printing management,and the use of remote dialogue/meetingtools available to the employees of the companies – Hub Agile and Vydio (on the workstation) – reduces travel. In addition,our data centres in Bourgesand Mordellesabide by the GreenGrid best practices –optimisation of energyconsumption.

FATCA, the US regulation to combat tax evasion by US citizens and residents; CRS: multilateral agreement with most OECD member countries on the (1) automatic exchange of financial account information. The indirect impacts associated with offerings, investments, or purchases are discussed in part 4.2.2. (2)

84 Universal Registration Document 2019 - GROUPAMA ASSURANCES MUTUELLES