Groupama // 2021 Universal Registration Document

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

The ethics whistleblowing 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’s companies were all mobilised in 2020 and 2021 to carry out their respective mappings, with a consolidated Group mapping produced as a result of this work. Regular updating of the mapping is planned. The Group incorporated modules specifically aimed at combating corruption and influence peddling for all its employees, in particular those most at risk (specialised modules according to activities), into its training programme. The most exposed personnel are identified from the risk mapping. In 2020, Groupama defined an action plan to strengthen its system for assessing the integrity of third parties with which the Group’s companies have a business relationship. In connection with the risk mapping, updates to the new relationship procedures were identified. The steering and monitoring of this work continued in 2021 in order to develop a Group digital solution to facilitate the integrity assessment of non-customer third parties. It should be noted that the third-party customer assessment system is based on the AML-CFT regulation. In general, the integrity assessment of all types of third parties can be subject to specific analyses by a specialised agency. The fight against money laundering and 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 group and each operational entity concerned, describes the mechanism in place with respect to informing and training employees exposed to these risks, and defines the methods and conditions for exchanges of 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 Group AML/CFT Officer is responsible for steering the Group’s AML/CFT system. In this context, its role is to: define the AML/CFT risk management policy; ❯ ensure the operational deployment of procedures and ❯ corresponding tools; ensure the coordination of the above-mentioned Managers’ ❯ channel; designing the 1 st level permanent control plan. ❯ The Group Compliance Director, as the key compliance function, ensures that the system is properly implemented in order to be able to assess AML/CFT risk at group level, in particular through a level 2 control plan. 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-corruption through e-learning: 2,985 people trained in 2021 (6,643 in 2020) or 13.2% of the workforce. AML/CFT training. Number of people trained (employee awareness): 2,268 training events completed in 2021 (3,993 in 2020). These training courses were implemented starting in early 2019. The 2020 data were recalculated to make the criterion to be used more reliable (difference between the notion of “trained person” - criterion used and the notion of “trainee”) Lastly, with regard to taxes, Groupama Gan Vie, the Group’s life insurance subsidiary, does not engage in business with 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 distribution networks, the identification of tax-delinquent customers in order to comply with the FATCA and CRS (1) regulations. It should also be noted that the Group signed a tax partnership with the tax authority (Service Partenaire des Entreprises) in 2019. Groupama is the only insurer among 50 French companies, which testifies to its taxpayer compliance insofar as the tax partnership reflects the cooperation and tax transparency with the authorities and therefore makes it possible to secure the Group’s tax management. A Group tax charter for internal use has been drafted.

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.

87 Universal Registration Document 2021 - GROUPAMA ASSURANCES MUTUELLES