UNIVERSAL REGISTRATION DOCUMENT 2023

8 ADDITIONAL INFORMATION Company information

WHICH FINANCIAL INSTRUMENTS ARE CONCERNED? In particular, they include any financial instrument traded on a regulated market or on a multilateral trading facility (MTF) or an organised trading facility (OTF): shares or other rights that grant or may grant access, directly or indirectly, to share capital or voting rights, debt securities, mutual fund shares or units, or derivatives. WHAT IS “INSIDE INFORMATION”? This is specific information that has not been made public, which involves, directly or indirectly, one or more issuers of financial instruments or one or more financial instruments and which, if it were made public, would be likely to have considerable influence on the prices of the financial instruments in question or the derivatives tied to them. Information is considered to be specific if it mentions a set of circumstances that exists or is reasonably likely to exist or an event that has happened or is reasonably likely to happen, when it is possible to conclude from the information the effect that those circumstances or that event could have on the prices of the financial instruments concerned. Information that, were it to be made public, would be likely to have considerable influence on the price of the financial instruments concerned is information that could be used by reasonable investors as one of the foundations of their investment decisions (buy, sell or hold). WHAT INFORMATION OR EVENTS RELATING TO AN ISSUER OF FINANCIAL INSTRUMENTS MAY BE CONSIDERED AS CONSTITUTING INSIDE INFORMATION? Examples include: earnings (or estimated earnings), and changes thereto that are higher or lower than announced forecasts; ❯ mergers, acquisitions, public offerings, joint ventures, disposals, or changes in assets, acquisitions of interest, major partnerships; ❯ major new products or changes involving customers or suppliers (such as the acquisition or loss of a customer or a major contract); ❯ major litigation, investigations, or proceedings conducted by the audit authorities; ❯ a one ‑ time event linked to the business, which may have a significant effect on earnings; ❯ events affecting the financial instruments of the issuer (failure to repay debt, early redemption, buyback programmes, division of par value or shares, modifications of dividends, changes to the rights of holders of financial instruments, public or private sales of additional financial instruments). ❯ This list is not exhaustive; other information may be considered as privileged depending on the circumstances. WHEN MAY INFORMATION BE CONSIDERED AS NOT PUBLIC? Information is not public when it has not been disclosed through, for example: an official press release, news service, or mass ‑ circulation daily newspaper; ❯

(g) Duty of secrecy: confidential information Directors, as well as any party called upon to attend all or part of the meetings of the Board of Directors and committees, are subject to an obligation of discretion as to the progress and content of the discussions. Specifically, Directors must maintain secrecy with regard to information corresponding to the definition of financial information, or other information likely to be of interest to third parties and specifically competitors of Groupama Assurances Mutuelles or the Group, or confidential information and data. They undertake not to use for personal purposes, and not to disclose outside the obligations of their position, any confidential information. Prevention of risk of insider trading This paragraph contains the rules of professional ethics intended to prevent the risk of insider trading, with regard to financial transactions pertaining to an issuer of financial instruments or financial instruments carried out by members of the Board of Directors, whenever Directors, in the exercise of their functions, hold or have access to inside information pertaining to that (h) Within one month after the close of the fiscal year just elapsed, Directors are also required to communicate the list of positions they have occupied during the year just elapsed with a view to preparing the management report. The applicable legislative and regulatory framework comes from the French Monetary and Financial Code and Regulation (EU) No. 596/2014 of 16 April 2014 on market abuse. The mechanism put in place is primarily based on the principle that any inside information concerning an issuer of financial instruments or financial instruments must not be unlawfully disclosed or used to carry out trades on one’s own behalf or on behalf of a third party directly or indirectly or by recommending to another person to carry out a trade. Failure to comply with the rules in this matter is punishable by law (prison term and major fine). The French financial markets authority (AMF) may alternatively prosecute these violations and impose pecuniary sanctions. Simplified definitions The definitions below have been simplified to facilitate a quick understanding of the key provisions of the regulations. For exhaustive details about these regulations, the complete texts issuer or those financial instruments. Legal and regulatory framework

are available from the general secretariat. WHO MAY BE CONSIDERED AN “INSIDER”?

Members of the Board of Directors, the Chief Executive Officer and any person having inside information in the course of his/her duties.

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Universal Registration Document 2023 GROUPAMA ASSURANCES MUTUELLES