NATIXIS -2020 Universal Registration Document

3 RISK FACTORS, RISK MANAGEMENT AND PILLAR III Risk management

Protection of clients 3.2.8.3 and investors

Handling of customer complaints This framework ensures that: customers receive transparent information on how their V complaints are being handled; complaints are handled effectively; and V correctiveaction is enforced to remedy any problems identified. V Financial security 3.2.8.4 The Financial Security Department reports to Compliance and manages the anti-money laundering and counter-terrorist financing (AML/CTF), corruptionand fraud prevention framework, and ensures that Natixis and its branches and subsidiaries comply with financial sanctions and embargoes. 2020 was a year marked by the continuationof the work undertaken concerning: managing the financial security system; V indicators used by the Financial Security Supervisory Committee V (AMLSOC) were harmonized for the parent company, subsidiaries and branches, both in France and abroad; increase the number of Natixis financial security teams; V the international sanction compliance framework, especially the V system for screening transactions and client databases; the KYC system, notably through revised and harmonized V governance and the launch of new KYC optimization and digitization projects; the implementation of an automated daily media watch on V Natixis S.A.’s business relationships; work on the convergence of the financial security systems of the V Asset Management entities and the Natixis M&A stores with the Natixis global system; the strengthening of the corruption risk mapping methodology, in V conjunction with BPCE, in line with AFA recommendations. Anti-money laundering and counter-terrorist financing As part of its efforts to combat money laundering and terrorist financing, in 2020 Natixis enhanced its AML-CTF framework by integrating the new requirements from texts and reports issued by French, European and international authorities and publicbodies. In accordance with the regulations in force, Natixis’ AML-CTFsystem primarily consists of the following items: in-depth and up-to-date information about the business V relationship, both before onboarding and throughout the relationship; a risk-basedapproachallowingclients to be classifiedaccording to V the money laundering and terrorist financing risks identified; a screening system for client databases and transactions that V uses automated tools or requests; an oversight system using permanent and periodic controls; V internal transmission of alerts and suspicions to the department V authorizedto report suspicions to the relevant financial intelligence units; a system for archiving and storing data relating to business V relationships and operations; an employee training and information system. V

The protection of customers’ interests is a core concern for Natixis that is reflected in the policies of every entity in France and abroad, as well as being included in its Code of Conduct. In all circumstances, employees are required to serve customers with diligence, loyalty, honesty and professionalism,and to offer financial products and services that are appropriate to customers’ abilities and needs. Accordingly, and in the interest of maintaining a high level of customer protection, Natixis strengthened its procedures and introduced additional controls. This resulted in the implementation of various systems used to manage KYC and other information, establish governance for products offered to clients and preserve their assets. For more informationon the GDPR and the protection of clients’ personal data see section 3.2.8.6 Protection of personal data. Client information There is a client informationprocedureencompassingall the MiFID 2 obligationswith respect to client onboarding, as well as the pre- and post-trade information due to clients based on their status as non-professional clients, professional clients or eligible counterparty as defined by regulations. There is also a specific procedure for cost and expense information, and key information documents for packaged products to be provided to non-professional clients, thus ensuring Natixis’ compliance with PRIIPS obligations. Know Your Customer (KYC) The procedures for customer onboarding are in line with the various regulatory requirements governing the prevention of money laundering and terrorist financing and compliance with embargoes and sanctions (AML-CTF), the prevention of corruption (Sapin II) and the preventionof tax avoidance (FATCA, AIE, DAC6). The onboarding procedures are also designed to protect customers through compliance with MiFID, EMIR and the Dodd-Frank Act. The customer contact entry tool has been rolled out across all Major Clients Banking locations. Protection of client financial instruments and funds If financial instruments or funds belonging to clients are held, the clients’ ownership rights to these assets are maintained and guaranteed. The use of client-owned financial instruments for the institution’sown purposes is only permitted if clients have previously given their express consent. Similarly, regulationsprohibit the signing of title transfer collateral arrangements with non-professionacllients. Product governance MiFID 2 and IDD (Insurance Distribution Directive) established the principle of product governance, which aims to define and regularly review a target market for all financial instruments and insurance products sold by Natixis and to ensure that the product was sold to the intended target. This includes ensuring that the distribution strategy is consistent with and appropriate for the target market. Product governanceapplies to all kinds of clients, regardless of their classification, and all products regardless of their level of complexity or trading venue. Adapting product governance, especially the definition and validation of the target market, to operations is handled through dedicated Committees.

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NATIXIS UNIVERSAL REGISTRATION DOCUMENT 2020