UNIVERSAL REGISTRATION DOCUMENT 2023

7 FINANCIAL STATEMENTS Combined financial statements and notes

The key role in verifying Groupama Assurances Mutuelles’ compliance, i.e. the Group Compliance Officer, is to: ensure, with the Compliance functional line and the heads of the Key Compliance Function, on behalf of the Group: ❯ facilitation, ■ oversight of compliance measures, ■ support for their deployment, ■ verification of the operational deployment of procedures and tools, ■ the design of level 1 and 2 control plans aimed at strengthening the control of non ‑ compliance risks, ■ the assessment of non ‑ compliance risk according to the applicable methodology by the Key Compliance Function, identifying, assessing, supervising, and monitoring the exposure to non ‑ compliance risks of the companies (risk mapping, dashboards, risk sheets, etc.); ■ relay, if necessary, information on legal, regulatory, and case law developments monitored by the Group Legal Department with the business line; ❯ regularly monitor compliance with Group policies, standards, and procedures and their effective implementation; ❯ contribute to the implementation and supervision, in collaboration with all Group entities, the tools for prevention, identification, and management of conflicts of interest; ❯ assist in drawing up replies to supervisory authorities, in particular with the Group Legal Department and the departments and companies concerned; ❯ help assess non ‑ compliance risks with regard to relations with customers and third parties in accordance with the requirements of the anti ‑ corruption section of the Sapin 2 law and the duty of care of parent companies and ordering companies; ❯ issue opinions, at the request of the heads of the Key Compliance Function of the Group companies, in the appropriate area of competence; ❯ report on non ‑ compliance risk management to the governance bodies of the Group and the companies. ❯ The work mainly focuses on themes and Major Group Risks (MGR). This involves covering, especially through ad hoc control plans, the non ‑ compliance risks identified in the Group operational risk mapping and, in particular, the MGRs identified by the Group. The Group Risk Management, Control, and Compliance Department oversees and coordinates the management of these MGRs, whose owners are departments designated by the Group. Laws or regulations that do not concern the Group’s core business ( e.g. labour law, corporate taxation, etc.) are considered to be outside the scope. Each Group entity has Risk Management, Control, and Compliance functions.

Defining the information systems security policy and its implementation by entities fall under the remit of Groupama Support and Services (G2S) which reports to the Group Operational Risk Management and Permanent Control Department. In addition, the Group Management Control Department is responsible for the ongoing monitoring of results and achievement of the Group’s objectives based on a process of estimated management common to all entities. This monitoring system also entails business reviews of subsidiaries conducted by the Senior Management of Groupama Assurances Mutuelles with business reviews at least twice a year.

2. 2.1

Insurance risks Prudential oversight

Pursuant to European Directives, Groupama is subject to regulations for covering the solvency margin, both at the corporate level for each of the insurance companies and at the level of the combined Group.

Objectives for managing risks resulting from insurance contracts and methods to limit these risks

2.2

2.2.1 The Group’s insurance business exposes it to risks primarily related to product design, underwriting, claims management, valuation of reserves, and reinsurance. Product design Most of Groupama’s business lines are subject to strong and increasing competition from other insurance companies, combined banking & insurance operations, and mutual insurance companies. This fierce competition places great pressure on the price of certain Groupama products and services and therefore on its profitability. The Insurance Divisions of Groupama Assurances Mutuelles ensure that the product line is in keeping with Group strategy. Life and non ‑ life insurance products are designed by, respectively, the business units of Groupama Assurances Mutuelles and Groupama Gan Vie on behalf of the Group’s companies. Product design is the result of market and profitability research performed with actuarial systems to control margins in conjunction with the Group Actuarial Department and the Investment Department where appropriate. Product launches or changes occur following a standard process incorporating the approval of the deliverables for customers and salespeople by the Group’s Legal, Risk Management, and Compliance Departments and are then adapted by division (regional mutuals, subsidiaries in France, international subsidiaries). Throughout the product governance procedure, metrics are built in to take target customers’ interests and characteristics into account. The main steps of this process are ratified in the committees stipulated (Operating Committees, Insurance Risk Committee, Group Executive Committee). New Life Insurance products are also presented to the GGVIE Regulatory and Environmental Management Committee

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Document d’Enregistrement Universel 2023 GROUPAMA ASSURANCES MUTUELLES