Groupama // Universal Registration Document 2022

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FINANCIAL STATEMENTS Combined financial statements and notes

Group and, working with the Group Accounting Department, prepares the report on the tax position of the consolidated 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, from 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 will also make it possible to generate additional savings on certain flows not previously covered by the regime for groupings. The current tax situation in France, as it appears in the Finance Act for 2023, is mainly marked for our companies by the abolition of the CVAE in two stages (total abolition in 2024), while the trajectory of the reduction in the rate of corporation tax, i.e. 25% excluding the additional contribution applicable from 2022 onwards, has not been called into question despite the attempts of certain members of parliament, just as those aimed at increasing taxation on exceptional profits or dividends have failed. As for the proposed “global minimum tax” adopted by the OECD, its transposition within the EU in the form of a proposal for a directive could be completed in 2023, with a possible implementation in 2024. The project is monitored by the Group Tax Department as well as by the Group Management Control Department, whose expertise is required in particular to understand the processing of data resulting from IFRS, which constitutes a factor of complexity and additional burden potentially associated with the future system, which would nevertheless have a limited impact on the Group’s tax burden at this stage of the work.

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 policies 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, it ensures that the tax consolidation rules are applied (Article 223 A et seq. of the French general tax code) for the as regards combating corruption and trading in influence (or influence peddling) (as per France’s Sapin 2 law) the key function of Compliance Manager at Groupama Assurances Mutuelles manages the operational implementation and updating of the anti ‑ corruption compliance programme in conjunction with the functions concerned. ❯ 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 role 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 2022 - GROUPAMA ASSURANCES MUTUELLES