UNIVERSAL REGISTRATION DOCUMENT 2023

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

4.2.7 FIGHT AGAINST CORRUPTION, INFLUENCE PEDDLING, MONEY LAUNDERING, TERRORIST FINANCING, AND TAX EVASION At the Group level, the implementation of measures to combat corruption and influence peddling as well as money laundering and terrorist financing (AML/CFT) is managed by the Group Compliance Department. The corresponding work is carried out in consultation with the Group’s Legal Department. The “Sapin 2” law of 9 December 2016 on transparency, the fight against corruption, and modernisation of the economy came into force on 1 June 2017. It introduces a general obligation to prevent risks of corruption and influence peddling for companies with more than 500 employees and 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 involves the operational implementation of eight measures, each of which has been the subject of specific work. The Group Compliance Department carried them out in consultation with the Group Compliance Department. Each Groupama group company has incorporated the Group Code of Conduct into its Internal Bylaws and has deployed an ethics whistleblowing system. Upon completion of the approval process by the staff representative bodies, all employees were informed of 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, which lists the rules to be adopted or prohibited for all employees in their activities, as well as the ethical alert system and the corresponding disciplinary sanctions in the event of non ‑ compliance with these rules; ❯ the ethics whistleblowing system allows all collaborators (employees, officers, or general agents as well as external and occasional collaborators) as well as individuals in contact with the Group (outside collaborators, contractors, etc.) to use a dedicated secure email address to report information about ❯

The ethics charter and the Code of Conduct apply to all Group companies, both French and international. The ethics charter is also available to third parties on the groupama.com corporate website. 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 have all mobilised to map out their respective corruption and influence ‑ peddling risks. A consolidated Group mapping was produced following this work and presented to the audit and Risk Committee. These mappings are regularly updated. The Group has included modules in its training programme specifically aimed at combating corruption and influence peddling for all its employees, as well as additional modules for its most exposed staff (specialised modules depending on the business activity). The most exposed personnel are identified from the risk mapping. These training courses were updated in 2023. 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 – Partner Assessment Portal (PEP’s) – 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 compliance officer): conflicts of interest, ■ 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 following areas to the authorised persons of their company (the head of the compliance verification function or

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Universal Registration Document 2023 GROUPAMA ASSURANCES MUTUELLES