UNIVERSAL REGISTRATION DOCUMENT 2023

3 CORPORATE GOVERNANCE AND INTERNAL CONTROL Internal control procedures

3.5.3

RISK GOVERNANCE

The major steps of the Group process for analysing assets/ liabilities and defining the investment strategy specified below are adapted to the level of each entity on the basis of their objectives and their own governance. The investment strategy is thus based on asset/liability analyses performed according to the issues of each company or portfolio and on expert analyses, taking into account the margins of prudence in view of the ALM conclusions . These analyses make it possible to determine: Groupama Asset Management, Groupama Immobilier, and outside Managers for market analyses; ❯ the financial and Actuarial Departments of the various entities for information about the liabilities of each entity. ❯ (1) the major arbitrage transactions to be considered in the portfolios; ❯ the investment guidelines by major asset class; ❯ the coverage requirements; ❯ the recommendations on the liability policies of the entities (underwriting policy in particular). ❯ On the basis of this work, the Group Investment Department then formalises the Group investment strategy defining the following elements: the strategic allocation at the Group level and on the main portfolios (stock); ❯ cash flow projections and areas of allocation on these flows; ❯ changes in strategies by asset class; ❯ policies specific to derivatives; ❯ investments on new asset classes; ❯ the risk budgets (budget of capital losses, coverage budget, IFRS result budget, capitalisation reserve allowance and writeback policy). ❯ The Group Investment Department verifies that this strategy complies with the Group risk limits. After this compliance verification is performed, the Group investment strategy is validated by: Group Executive Committee; ❯ the Group Audit and Risk Management Committee; ❯ the Groupama Assurances Mutuelles Board of Directors. ❯ After the Group investment strategy is validated, the Investment Department deploys this strategy operationally at the level of: each French subsidiary; ❯ each international subsidiary; ❯ certain contractual or regulatory administrative districts (for French subsidiaries). ❯ In the Groupama Assurances Mutuelles subsidiaries, the investment strategies are validated during financial committee or asset allocation committee meetings, depending on their organisation. In the regional mutuals, investment strategies are validated during their financial committee meeting, in keeping with the Group’s investment strategy.

3.5.3.1 Group Risk Management Committee (CRG) Its membership is the same as that of the Group Executive Committee. Its tasks are to approve the risk management policy and the policies by risk area, particularly by setting the limits of major risks and determining the methods to be used to manage risks, to review and monitor the management of major Group risks and to examine the work of the Group Insurance, Financial, and Operational Risk Management Committees. These specialist committees cover all risks with a systematic focus on major Group risks. They ensure continuity of action from the Group Risk Management Committee to which they report up to the working groups and committees in charge of activities incurring risks. The specialist committees are chaired by a member of the Group Executive Committee. The Group risk management and Compliance Department provides coordination and secretarial support to these committees. The Group financial risk management committee is made up of the deputy Chief Executive Officer (Chairman), the heads of the Group finance and investment departments, the Group risk management and compliance Director, and representatives of the French Subsidiaries/International Subsidiaries Departments and banking and Asset Management subsidiaries. It is responsible for proposing to the Group Risk Management Committee the policy and rules governing the acceptance and retention of financial risks. In this context, it: identifies and evaluates financial risks; ❯ proposes asset risk limits at Group level and entity level as well as hedging principles; ❯ checks the proper application of these limits by the Group’s entities and proposes action plans; ❯ validates any exemptions and/or the establishment of action plans; ❯ reviews the models and methodologies for assessment of financial risks ( e.g. Asset/Liability Management, valuation, etc.) and the limits of these models; ❯ defines stress test scenarios for financial risks, evaluates their consequences, and proposes a modus operandi in case of occurrence of a financial shock; ❯ alerts the Group’s Executive Management where appropriate. ❯ (a) The bodies dedicated to risk management enabling the Groupama Assurances Mutuelles Executive Management to carry out regular monitoring of the main risks incurred at Group level are the Group Risk Management Committee and the specialist Group committees for the various risk categories (Financial Risks, Insurance Risks and Operational Risks) and the Capital Management Committee. Group Financial Risk Management Committee (CRFG)

(1) Asset and Liability Management.

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Universal Registration Document 2023 GROUPAMA ASSURANCES MUTUELLES