NATIXIS - 2018 Registration document and annual financial report

NON-FINANCIAL PERFORMANCE REPORT The Natixis Code of Conduct and its implementation

IMPLEMENTATION OF THE CODE 6.2.2 OF CONDUCT AT NATIXIS

CODE OF CONDUCT General conduct and guiding principles

Appropriation by employees A communications campaign was organized in March 2018 following the publication of the Code of Conduct and a new page was added to the Natixis website and Intranet. All staff are required to complete mandatory training on the Code of Conduct and must each commit to complying with the rules. In 2018, more than 99% of members of staff from all departments and all regions received e-learning or face-to-face training. Managers and leaders also ensure that their teams understand and adhere to the Code of Conduct and to the internal policies and procedures ensuring its application. Bespoke governance The Global Conduct Committee was set up in June 2018. It is chaired by the Chief Executive Officer and is formed of members of the Natixis Senior Management Committee. The Committee is governed by a Charter that describes its duties and how it functions. The Global Conduct Committee is responsible for all matters concerning the Natixis Code of Conduct and its application by all subsidiaries and direct branches. It is in charge of the oversight and regular monitoring of matters pertaining to the rules of conduct, including updates to the Code and deciding on complex cases. An escalation process is also in place to consult the Committee if required. The Committee met three times in 2018 to discuss individual cases, approve ESR procedures, and supervise the roll-out of the Code. Global Conduct Policy All the Natixis business lines and support functions are in charge of adapting the principles of the Code to their activities. Accordingly, conduct matters have been included in the governance of different Group entities via existing or newly created Conduct Committees. Governing that are the rules set out in the Global Conduct Policy, which outline: the responsibilities imposed by the Code of Conduct and, a specifically, how conduct must have a bearing on decisions, both strategic and operational, and on individual behavior; the terms of governance and reporting; and a risk assessment, monitoring of indicators, and the control a system. The committees all met at least once in 2018 and reviewed any shortfalls—human resources, risk, compliance or other—with respect to the Code, ensuring that these shortfalls are addressed in the annual appraisals of the employees concerned. Operating procedures Compliance with the Code of Conduct is, among others, ensured by the observance of internal policies and procedures. The Code of Conduct is a master document and internal policies and procedures must be consistent with its provisions.

Governance and processes to ensure

POLICIES

the operational application

PROCEDURES

Training and communication

The policies and procedures that apply the principles of the Code of Conduct include: risk policies (see section 3.2.3) a the corpus of procedures issued by the Compliance Department a (procedures on anti-corruption, anti-money- laundering/terrorist- financing, conflicts of interest, professional ethics, etc.) relating

to non-compliance risks (see section 3.2.8) ; ESR sectorial policies (see section 6.4.1) a

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Responsible purchasing charter (see section 6.4.2) a HR agreements and procedures (see section 6.6.1). a

Also in 2018, Natixis adopted the Charter for Responsible Lobbying and Advocacy Activities with respect to Governmental Bodies and Officials, available on its website. (https://www.natixis.com/natixis/jcms/rpaz5_65435/fr/code-de- conduite). With this charter, Natixis ensures the integrity and probity of its lobbying activities in compliance with its Code of Conduct and applicable laws, rules and regulations. It applies to all entities controlled by Natixis and to their employees. It covers lobbying and advocacy activities, which are coordinated by Natixis’ Public Affairs Department and its parent company, BPCE. Natixis believes that dialog and respectful discussion of diverging interests are necessary to ensure the correct functioning of the democratic process. To this end, it engages in dialogue with public and government officials on proposed legislative and regulatory requirements that impact Natixis’ business as well as its ability to serve its clients. Natixis is registered with the competent European and national authorities and undertakes to observe the applicable codes of conduct. It has been included in the European Transparency Register since 2017 and is also registered in the French public register of lobbyists with the High Authority for Transparency in Public Life. To combat tax avoidance, Natixis has control systems to ensure its transactions comply with tax laws and regulations. All new products, new activities and exceptional transactions must be approved with regard to these laws and regulations. In addition, Natixis reports transparently on its organizational structure and operations, and discloses its revenues and the corresponding taxes on a country-by-country basis for greater clarity on the determining factors of its tax expense. It has also adopted the UK HM Revenue & Customs Code of Practice on Taxation for Banks.

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Natixis Registration Document 2018