NATIXIS - 2018 Registration document and annual financial report

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

Natixis observes transparency rules intended to combat tax avoidance in France and around the world. It applies the Common Reporting Standard (CRS) for the Automatic Exchange Of Information (AEOI) on income received by participating countries’ tax residents abroad, as well as US FATCA regulations to prevent tax avoidance involving foreign accounts or entities owned by US taxpayers. (See Chapter 3.2.8.3 Client protection—Know Your Client.)

Natixis also incorporates tax fraud in its anti-money laundering system. (See Chapter 3.2.8.4 Financial security.) In general, Natixis maintains professional relations and cooperates with all the tax authorities in the countries in which it does business. Finally, the code of conduct and the policies and procedures that complement its principles does not have a rule for every situation: it is the responsibility of each individual to exercise his or her personal judgment with regard to their duties and to demonstrate meticulous professional ethics. To do so, the following conduct checklist is provided.

CONDUCT CHECKLIST

While the Code of Conduct, as well as relevant internal policies and procedures, provide clear guidelines for behavior, not every situation that arises in day-to-day activities can be directly covered by a rule. Making the right decision will require personal judgment, taking account of Natixis DNA and the spirit of the Code of Conduct principles.

If you are unsure about the consistency of what you intend to do with the Code of Conduct guidelines, ask yourself:

WOULD I BE CONFORTABLE EXPLAINING THE DECISION TO A THIRD PARTY (supervisor, in court) OR READING ABOUT IT IN THE HEADLINES?

DOES IT COMPLY WITHOUR CULTURE PROMOTING THE BEST INTEREST OF THE CLIENT OVER THE LONG TERM?

HAVE I CONSIDERED ALL THE RISKS INVOLVED FOR NATIXIS OR GROUPE BPCE?

DOES IT COMPLY WITH THE LETTER OF OUR POLICIES & PROCEDURES?

yes

yes

yes

yes

IS IT LEGAL?

no ?

no ?

no ?

no ?

no ?

If the answer to one of these questions is no, or if you are unsure about it, please seek guidance from an appropriate authority: Ask for help from your line manager, or relevant teams (e.g., Compliance, Environmental and Social Responsibility (ESR), Human Resources, Legal).

Escalate to the relevant committee (ultimately to the Natixis Conduct committee)

Whistleblowing procedure The whistleblowing procedure is an integral part of the Conduct system. It allows any member of staff who becomes aware of an inappropriate act or behavior (illegal acts, unethical behavior, violation of the Code of Conduct or the applicable policies and procedures) to inform the competent body within Natixis and receive the guarantees and protection set forth bylaws and regulations. This procedure is based on a global policy that forms the minimum standard to be applied across Natixis Group. At Natixis S.A., a procedure published in July 2018 updated the existing policy to take into account the latest regulatory changes. The whistleblowing procedure is open to: all individuals with a current employment contract with a Natixis, regardless of the type or duration of the contract; employees of external companies (suppliers or subcontractors) a who work with Natixis either on a permanent or irregular basis.

The process sets out a clear timeline, with: immediate acknowledgment of the report; a

notification within 15 business days of the date of a acknowledgment of whether the information reported is eligible for further investigation; notification within three months of the date of acknowledgment a of the steps taken to process the information reported or, if this process has been completed, the action taken (or not taken) based on the information. The procedure provides protection to the whistleblower (who may in no circumstances be subject to disciplinary action or legal proceeding provided they have acted impartially and in good faith) and ensures the information is treated appropriately and in full confidence, in accordance with the applicable regulations. At Natixis, each entity, subsidiary and branch office must adapt the overall policy to its activities and specific situation and/or ensure that the policy complies with its own procedures and local regulations.

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Natixis Registration Document 2018