Groupama // 2021 Universal Registration Document

8 ADDITIONAL INFORMATION Regulatory environment

The AML/CFT systems of international subsidiaries may vary according to national legislation and, for those established in the European Union, according to the transposition of the directives on the subject. In groups, French regulations require parent companies to define at the Group level an internal organisation and procedures taking into account the assessment of money laundering and terrorist financing (ML/FT) risks and to ensure that this organisation and these procedures are deployed by their international subsidiaries, taking into account their specific characteristics and the ML/FT risks to which they are exposed. The Group’s regulated companies, including insurance companies, are subject to obligations to assess their ML/FT risks, conduct customer due diligence measures, and report suspicious transactions. They must be equipped with appropriate tools and control mechanisms as well as sufficient physical and human resources to enable these obligations to be effectively implemented. The system of supervision and sanctions for regulated professionals has been strengthened. In France, the ACPR is responsible for monitoring compliance with these obligations for the financial sector and has the power to impose sanctions. In addition to the national accounting standards to which each of the Group’s entities is subject, the Group has applied since 2005 for the preparation of the combined financial statements the provisions of the International Financial Reporting Standards (IFRS) and the interpretations applicable to the closing of accounts as adopted by the European Union. The main methods of their application by Groupama Assurances Mutuelles are described in the notes the combined financial statements (see paragraph 7.1.6-point 2 of this Universal Registration Document). The combined financial statements relate to Groupama Group and include all local mutuals, regional mutuals, Assurances Mutuelles, and its subsidiaries. Subsidiaries, joint ventures, and related companies of the consolidation scope are consolidated within the scope in accordance with the provisions of IFRS 10, IFRS 11, and IAS 28. However, no IFRS standard specifically deals with the methods for aggregating the financial statements of entities forming the Mutual Insurance Division (local mutuals and regional mutuals). The Group has therefore adopted the combination rules defined in section VI of Regulation no 2000-05 of the Accounting Regulatory Committee related to the rules for consolidation and combination of companies governed by the French Insurance Code and provident institutions ACCOUNTING STANDARDS 8.3.5

governed by the French Social Security Code or by the French Rural Code. This choice was made in accordance with the judgement criteria of article 10 of IAS 8 (on the selection and application of accounting policies in the absence of a standard or an interpretation that is specifically applicable) owing to the characteristics of Groupama’s Mutual Insurance Division. The Group has opted to defer the application of IFRS 9 “Financial Instruments” and its amendment “Prepayment Features with Negative Compensation” in accordance with the amendments to IFRS 4 “Applying IFRS 9 Financial Instruments with IFRS 4 Insurance Contracts” and “Extension of the temporary exemption from applying IFRS 9”, which allows groups whose main business is insurance to postpone the application of IFRS 9 at the latest until the annual periods beginning on or after 1 January 2023. The Group meets the eligibility criteria defined in the amendment to defer the application of IFRS 9. IFRS 17 on insurance contracts, which will replace the current IFRS 4, was adopted in November 2021 by the European Union with, in relation to the provisions of the standard and its amendments published by the IASB in May 2017 and June 2020, an optional exemption from the requirement for annual cohorts in certain specific cases. Work to identify problems in implementing this standard and its impact on the combined financial statements is currently in progress. This work is being carried out in conjunction with the IFRS 9 impact analysis and takes into account the postponement of the effective date of IFRS 17 and IFRS 9 to 1 January 2023. Beyond the regulations specific to insurance or the financial sector, the Group’s entities, like any economic agent, must comply with the general regulations applicable in the country where they operate. In particular, the law of 9 December 2016 on transparency, the fight against corruption and the modernisation of economic life, known as “Sapin II”, requires large companies to have a system for preventing, detecting, and managing the risks of corruption and influence peddling in France or abroad or face administrative or criminal sanctions. The French Anti-Corruption Agency issues guides and recommendations for regulated players. In this respect, the Group implemented an anti-corruption programme including risk mapping, a process for evaluating customers and third parties, a monitoring and training programme, and a Code of Conduct, incorporating whistleblowing, for employees. OTHER REGULATIONS 8.3.6

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Universal Registration Document 2021 - GROUPAMA ASSURANCES MUTUELLES