Groupama // Universal Registration Document 2022

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

The Group compliance Director, as the key compliance function, ensures that the system is properly implemented in order to be able to assess AML/CFT risk at Group level, in particular through a level 2 control plan. Reports are regularly made to the senior management of Groupama Assurances Mutuelles and to the Group’s governance bodies. Performance indicator Corruption prevention training. Number of employees trained in ethics and anti ‑ corruption through e ‑ learning: 3,502 people trained in 2022 (2,985 in 2021) or 15.4% of the workforce (13.2% in 2021). AML/CFT training. Number of people trained (employee awareness): 1,492 training events completed in 2022 (2,268 in 2021). Taking into account specific training (5 modules), a total of 9,725 employees received AML/CFT training in 2022 (10,577 in 2021). These training courses were implemented starting in early 2019. The 2020 data were recalculated to make the criterion to be used more reliable (difference between the notion of “trained person” - criterion used and the notion of “trainee”). Lastly, with regard to taxes, Groupama Gan Vie, the Group’s life insurance subsidiary, does not engage in business with customers who are not French taxpayers in the course of its business activities. However, the Company’s distribution processes have provided for, through its sales support tools deployed in the distribution networks, the identification of tax ‑ delinquent customers in order to comply with the FATCA and CRS regulations. It should also be noted that the Group established a tax partnership with the tax authority (partner service for companies). Groupama is the first insurer among around 60 French companies to have such a partnership, which testifies to its taxpayer compliance insofar as the tax partnership reflects the cooperation and tax transparency with the authorities and therefore makes it possible to secure the Group’s tax management. A group tax charter for internal use has been drafted. ensure the coordination of the above ‑ mentioned Managers’ channel; ❯ designing the 1 level permanent control plan. ❯ st (2)

Focus on 2022. Broadening the status of whistleblowers and strengthening its protection The law of 21 March 2022 transposes into French law the European directive of 23 October 2019 on the protection of persons who report violations of European Union law. The ethics charter, Code of Conduct, and whistleblowing system have been amended accordingly. Employees, agents, general agents - and now persons “connected” with Groupama’s companies - may exercise the right to alert if they suspect or witness acts contrary to the charter or the code or if they have information on crimes and offences or violations (as set out in Article 6 of the Sapin 2 law as amended). The process for approving these changes by the employee representative bodies will continue in 2023. A Code of Conduct for external third parties will be posted on the Group’s websites in 2023. The fight against money laundering and terrorist financing is also an important issue for the Group’s companies subject to such regulations. The system is managed by the Group Compliance Department. which ensures that the Group complies with its obligations in conjunction with a network of AML/CFT Managers appointed in all of these entities, both in France and internationally. An AML/CFT organisational chart defines the roles and responsibilities of the various participants and stakeholders at the level of the Group and each operational entity concerned, describes the mechanism in place with respect to informing and training employees exposed to these risks, and defines the methods and conditions for exchanges of information required for due diligence. In addition, it specifies the applicable risk monitoring and control system. The Group Legal Department ensures dedicated legal and regulatory monitoring as well as interpretation of standards/ sanctions. The Group AML/CFT Officer is responsible for steering the (1)

Group’s AML/CFT system. In this context, its role is to:

define the AML/CFT risk management policy; ❯ ensure the operational deployment of procedures and corresponding tools; ❯

(1) (2)

Former employees and job applicants, shareholders/partners/holders of the right to vote in the entity’s General Meeting, members of the administrative/ management body, contractors/subcontractors, and members of their administrative/management body. FATCA, the US regulation to combat tax evasion by US citizens and residents; CRS: multilateral agreement with most OECD member countries on the automatic exchange of financial account information.

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Universal Registration Document 2022 - GROUPAMA ASSURANCES MUTUELLES