UNIVERSAL REGISTRATION DOCUMENT 2023

7 FINANCIAL STATEMENTS Combined financial statements and notes

it ensures that the tax consolidation rules are applied (Article 223 A et seq. of the French General Tax Code) for the Group and, working with the Group Accounting Department, prepares the report on the tax position of the combined companies. It also helps to implement documentation and archiving procedures in terms of computerised accounting records, as required under tax law, particularly as part of dedicated “CFCI” (Computerised Accounting Tax Audit) committees for each French entity. In addition, the Group Tax Department coordinates, in a Steering Committee, the implementation and monitoring of regulations on the automated exchange of tax data, in particular resulting from the American FATCA (Foreign Account Tax Compliance Act) regulations and the transposition of the European DAC (Directive for Administrative Cooperation). Lastly, as regards transfer pricing, it performs an annual update of the Master File meeting the new French requirements under the OECD standards and sends its English version to all international subsidiaries. In France, the Group’s tax management benefits from the establishment of a tax partnership between Groupama and the DGFIP, since the signing of a protocol on 26 June 2019 with the SPE (Business Partner Service), which now represents a very effective tool for its tax policy and communication. Furthermore, since 1 January 2023, the internal transactions of most French entities, subsidiaries, or regional mutuals will not be subject to VAT under the “VAT Group” regime, which replaces that of groupings of resources under French tax regulations, and for which the Group has opted in order to retain the benefit of a very substantial non ‑ recoverable VAT savings. This option also makes it possible to generate additional savings on certain flows not previously covered by the regime for groupings. For our Group, the main tax developments in France, as reflected in the Finance Act for 2024, are the transposition into French law, as from 1 January 2024, of the worldwide minimum tax adopted by the OECD and adopted by the EU in a Directive. The project is being monitored with a view to the first reporting date of 30 June 2026 by the Group Tax Department and the Group Consolidation Department, whose expertise is required, in particular, to understand the processing of data derived from IFRS, which adds to the complexity and burden of this system. However, at this stage of the work, the impact on the Group’s tax charge would be limited. The 2024 Finance Act also sets out the timetable for two key tax reforms for the Group: the staggered elimination of the CVAE from 2024 to 2027 and the postponement of the entry into force of electronic invoicing to 1 September 2026. Groupama generally remains vigilant on the future interpretations or developments of the tax systems in the countries in which it operates that could lead to an increase in tax expenditures, generate compliance costs, or adversely affect the Group’s activity, cash position, and net income.

5.3 Tax risks Changes to the tax laws of countries where Groupama operates may have adverse consequences either on some Group products and reduce their attractiveness, especially those that currently receive favourable tax treatment, or on the Group’s tax expense. Examples of such changes include the taxation of life insurance contracts or annuities contracts, changes in the tax status of some insurance or asset management products and tax incentives or disincentives to investing in some asset classes or product categories. The role of the Group Tax Department is to provide information, monitor regulations, and advise and assist in the event of tax audits and disputes for all of the Group’s entities and with regard to the “corporate taxation” component. It is regularly approached about specific underwriting points and is involved in preparing the end ‑ of ‑ year financial statements. In this capacity, as regards combating corruption and trading in influence (or influence peddling) (as per France’s Sapin 2 law) the Compliance key function at Groupama Assurances Mutuelles manages the operational implementation and updating of the anti ‑ corruption compliance programme in conjunction with the functions concerned. ❯ Managers and the regional mutuals, ensure the Group is meeting its obligations in this respect; with regard to the protection of medical data, Group recommendations are disseminated by the Groupama Assurances Mutuelles business division concerned or entity concerned. It is the responsibility of the various Group entities (regional mutuals and subsidiaries) to implement these recommendations, in partnership with medical advisers and the Group Data Protection Officer (DPO), and the claims unit of the Group Insurance and Services Department; ❯ as regards the protection of customers, the key Compliance function at Groupama Assurances Mutuelles helps with operational implementation of several issues, including: ❯ ACPR instruction 2022 ‑ I ‑ 11 on the questionnaire about commercial practices and protection of customers, ■ various ACPR recommendations, ■ monitoring of the major Group risk of “failure to advise”, ■ monitoring of the Insurance Distribution Directive, which also includes product governance, the prevention and management of conflicts of interest, compensation of distribution networks, and professionalism and CPD, ■ the ongoing enhancement of the permanent control system, ■ monitoring and implementation of action plans to improve marketing measures (OAV); ■

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Universal Registration Document 2023 GROUPAMA ASSURANCES MUTUELLES