NATIXIS_REGISTRATION_DOCUMENT_2017

PRESENTATION OF NATIXIS Natixis Code of Conduct

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These guidelines are illustrated using examples that are representativeof the activitiesand dutiesperformedat Natixis. All the Natixis businesslines and support functionsare in charge of adapting, from an operational standpoint and with the assistance of the ComplianceDepartment,the principles of the Code to the performanceof their activities. A Conduct Committee, comprising members of Natixis’ Senior Management Committee, is in charge of the oversight and

regular monitoringof matters pertaining to the rules of conduct, including updates to the Code and deciding on complex cases. An escalationprocessis also in place to consultthe Committeeif required. The Code of Conduct does not, however, have a rule for every situation: it is the responsibilityof each individualto exercise his or her personal judgment with regard to their duties. To do so, the followingconductchecklistis 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)

All staff are required to complete mandatory training on the Code of Conduct and must each commit to complyingwith the rules. Managers and leaders also ensure that their teams

understand and adhere to the Code of Conduct and to the internalpoliciesand proceduresensuringits application.

The Code of Conductis availableon the Natixiswebsite https://www.natixis.com/natixis/jcms/rpaz5_65435/en/code-of-conduct

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Natixis Registration Document 2017

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