GROUPAMA / 2020 UNIVERSAL REGISTRATION DOCUMENT

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

The fight againstmoney launderingand terrorist financing is also an important issue for the Group’s companies subject to such regulations. The system is managed by the Group Compliance Department, which ensures that the Group complies with its obligations in conjunction with a network of AML/CFT Managers appointed in all of these entities, both in France and internationally. An AML/CFT organisational chart defines the roles and responsibilities of 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 for exchangesof information required for due diligence. In addition, it specifies the applicable risk monitoring and control system. The Group Legal Department ensures dedicated legal and regulatory monitoring as well as interpretation of standards/sanctions. The GroupComplianceDepartmentis responsiblefor managingthe Group’s AML/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 order to have a centralised view of risk management. To this end, the Group Compliance Department manages the network of the above Managers. 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-corruptionthrough e-learning: 8,544 peopletrained in 2020, or 38.2% of the workforce (15,023 in 2019). AML/CFT training. Number of people trained (employee awareness): 3,993 training events completed in 2020 (4,663 in 2019) These training courses were implemented starting in early 2019. The special circumstancesof 2020 explain the fewer trainingevents than in 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 order to comply with the FATCA and CRS (1) regulations.

The “Sapin 2” law of 9 December 2016 on transparency, the fight against corruption, and modernisationof the economy came into force on 1 June 2017. It introducesa general obligation to prevent risks of corruptionand influencepeddling for companieswith more than 500 employeesand revenue of more than €100 million.Once a group is subject to this obligation, its subsidiaries located in France or abroad are affected by this obligation. This regulation requires the operational implementation of eight measures. Each Groupama group company has incorporated the Group Code of Conduct into its Internal Bylaws and has deployed an ethics whistle-blowing 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 ❯ commitments adopted by the Group; the Code of Conduct lists the rules for all employees in their ❯ activities as well as the ethics whistle-blowingsystem and the corresponding disciplinary measures for violating these rules; the ethics whistle-blowing system allows 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 Compliance Verification Function or the Compliance Officer): corruption, influence peddling, ■ violations of human rights and fundamental freedoms, ■ harm to the environment, ■ internal fraud, ■ crimes or offences, ■ threat or severe harm to the public interest. ■ The ethics charter and the Code of Conduct apply to all group companies, both French and international. As part of its plan to prevent risks of corruption and influence peddling, Groupama bolstered its Code of Conduct with illustrations related to risk mapping in 2020. The Group incorporatedmodules specifically aimed at combating corruptionand influencepeddling for all its employees, in particular those most at risk (specialisedmodulesaccordingto activities), into its training programme.The most exposed personnel are identified from the risk mapping. In 2020, Groupamadefined an action plan to strengthenits system for assessing the integrity of third parties with which the Group’s companieshave a business relationship.In connectionwith the risk mapping, updates to the new relationship procedures were identified. The steering and monitoringof this work will continue in 2021.

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.

90 Universal Registration Document 2020 - GROUPAMA ASSURANCES MUTUELLES