NATIXIS // 2021 Universal Registration Document

RISK FACTORS, RISK MANAGEMENT AND PILLAR III Risk management

In accordancewith the regulations in force, Natixis’ AML-CTFsystem primarily consists of the following: in-depth and up-to-date information about the business V relationship, both before onboarding and throughout the relationship; a risk-based approach allowing clients to be classified according V to the money laundering and terrorist financing risksidentified; 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 suspicious activity to the V department authorized to report suspicious activity to the relevant financial intelligence units; a system for archiving and storing data relating to business V relationships and transactions; an employee training and information system. V Natixis Financial Security continued to strengthen its monitoring tools in 2021. Furthermore, the a priori AML-CTF referral criteria used by Natixis S.A.’s Financial Security were strengthened and redefined as part of reinforcing monitoring across the consolidated scope of Natixis S.A. and its subsidiaries. Accordingly, before a transaction or financing can be prepared, an opinion on cases that meet one or more criteria on the list of referral criteria must be provided by Natixis S.A.’s Financial Security. As for counter-terrorist financing, Natixis continued its work on the CTF risk map based on an assessment of the exposure of Natixis’ business lines, branches and subsidiaries. In addition, the geopolitical watch report is distributed internally, thereby keeping people informed of the latest developments in this area and providing them with guidelines on implementing appropriate vigilance measures and dedicated controls. Compliance with financial sanctions and embargoes Natixis has a framework of internal policies and procedures, screening tools, training and permanent supervision controls ensuring compliance with the financial sanction and embargo regulations to which it is subject. The framework draws on measures for verifying client databases and screening transactionswith a view to identifying, on an ongoing basis, any person or entity subject to financial sanctions, specifically account freezes or restrictedaccess to bank financing. This makes it possible to freeze the accounts or transactionsof Natixis customers as quickly as possible. It is also able to prevent any transactions linked to sectors, goods or technologies that are subject to restrictions or bans pursuant to embargo measures. Jurisdictions subject to embargo undergo constant supervision and heightened diligence as part of a prudent and restrictive approach. A team of experts dedicated to financial sanctions provides specific assistance and advice to the Bank’s business lines and entities.

In 2021, Natixis continued to strengthen its system of compliance with international sanctions, notably with the implementationof new changes to its screening tools and lists. Prevention of corruption In accordance with the requirements introduced by Article 17 of the law of December 9, 2016 on transparency, the fight against corruption and the modernization of the economy (known as the Sapin 2 law), and based on the recommendationsand guides of the French Anti-Corruption Agency (AFA), Natixis has strengthened certain rules and procedures in its compliance system to bring them up to the highest international standards in terms of preventing corruption. Natixis’ Chief Executive Officer is responsible for the corruption prevention program. The anti-corruption framework as a whole is managed and coordinated by a dedicated team within Compliance’s Financial Security Department. It relies on a network of anti-corruption officers within all of Natixis’ business lines, subsidiaries and branches, in France and abroad. Governance is ensured through dedicated Committees. The anti-corruption system includes: a regularly updated corruption risk map; V standards and procedures. This includes a policy dedicated to the V prevention and detection of corruption, communicated to all employees, as well as internal regulations incorporatingthe rules in this area and illustrations of the behaviors to be prohibited, resulting from the mapping exercise of corruption risk. The various high-risk situations are also managed through dedicated procedures, such as the procedures for preventing and managing conflict-of-interest situations, conducting anti-corruption due diligence when initiating business relationships with third parties (including clients, intermediaries and suppliers) and prior to forming partnerships or carrying out merger and acquisition transactions, and supervising recruitment. High-risk practices, including giving/accepting gifts or invitations, sponsorship initiatives, sponsoring, donations and third-party compensation, are also governed by specific procedures; a control system. The corruption aspects are fully incorporated V within the existing permanent control system, particularly through specific controls covering high-risk situations and practices and they are included in accounting procedures and controls; a whistleblowing system. The corruption prevention program is V based on Natixis’ alert system. Natixis employees can use the whistleblowing system to report any facts or events they encounter that may indicate corruption or influence peddling; a training system. To ensure that these rules and procedures are V disseminated and adopted, compulsory e-learning training has been rolled out for all employees and specific training sessions have been held for the members of Natixis’ Executive Committee and employees who are most likely to be exposed to corruption risk. In addition to the French regulations that apply to all Natixis entities, Natixis ensures strict compliance with the local regulations applicable to its foreign operations, such as the UK Bribery Act and the US Foreign Corrupt Practices Act. The main corruption prevention program rules and procedures can be found in Natixis’ anti-corruption policy, available at www.natixis.com .

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NATIXIS UNIVERSAL REGISTRATION DOCUMENT 2021