Groupama // Universal Registration Document 2022

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CORPORATE GOVERNANCE AND INTERNAL CONTROL Internal control procedures

The Group HR Department also carries out social projects in the consolidated companies, relating to the obligations of transparency and non ‑ financial reporting covered in the Grenelle II law (publication in the management report of information relating to social impacts – organisation of work, labour relations, diversity, etc.). Note that after audit and verification by the statutory auditors, Groupama successfully obtained for 2022 (like the previous year) a certificate of participation as well as an attestation of sincerity.

As auditing is part of the internal control procedure, a Group and Groupama Assurances Mutuelles audit policy supplements the provisions of the internal control policy with its own operating rules and scope of operation. Risk management policies as well as a compliance policy, defining the overall framework for implementation and operation of the compliance system within the Group, complete the general internal control system. In accordance with the requirements of Solvency II, a gap analysis is conducted annually on each of the policies to verify whether they should be updated. The internal control system deployed by the Group is based on commonly accepted practices . It covers the first ‑ level and second ‑ level Permanent Control system as well as periodic control (or third ‑ level control). Permanent Control is implemented by: (1) operational units that provide first ‑ level control; ❯ teams specifically dedicated to Permanent Control (risks, compliance with laws and regulations, accounting control, security of information systems, etc.) that provide second ‑ level control. ❯ The internal audit function periodically assesses the adequacy and proper functioning of the Permanent Control system and provides a third level of control. The various business lines are responsible for the risks that they generate through the operations that they carry out. They ensure and assume the first ‑ level controls on their scope of responsibility. Second ‑ level and third ‑ level controls are usually the responsibility of the specialised departments: the Group Risk Management, Control, and Compliance Department; ❯ the Audit Department. ❯ However, certain second ‑ level Permanent Controls may be conducted by dedicated departments according to the organisation of the activity (Accounting Department, Information Systems Security Department, Legal Department, etc.).

3.5.2

INTERNAL CONTROL ORGANISATION AT THE GROUP LEVE

Internal control is a mechanism that the Group implements to guarantee: the application of instructions and guidelines set by executive management; ❯ compliance with the laws and regulations, local rules and Codes of conduct relating to the businesses carried out by the Group; ❯ the proper functioning of the internal processes and rules of each company, particularly those contributing to the safeguarding of the Group’s assets; ❯ the reliability of financial data; ❯ the control of risks of any nature to which each company is exposed; ❯ and, in general, contribute to the control of its activities, the effectiveness of its operations and the efficient use of its resources. ❯ Beyond compliance with the regulatory obligations, the implementation of an internal control system constitutes a strategic issue for Groupama essential to the preservation of its interests, the interests of its customers, partners, members and shareholders, and the interests of its staff or even its existence in case of a major event. In this context, the general principles, objectives, and organisation of internal control of the Group and Groupama Assurances Mutuelles were defined in a policy approved by the Board of Directors of Groupama Assurances Mutuelles in 2018. For the Group’s entities, this policy constitutes the common reference to be respected in the deployment of their internal control processes.

(1) Inspired by the IFACI’s work and using the COSO as a reference.

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Universal Registration Document 2022 - GROUPAMA ASSURANCES MUTUELLES