NATIXIS - Universal registration document and financial report 2019

6 NON-FINANCIAL PERFORMANCE REPORT Employee conduct and business ethics

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. Local adaptations are covered by rules set out in the Global Conduct Policy, which outline: the responsibilities imposed by the Code of Conduct and, V specifically, how conduct must have a bearing on both strategic and operational decisions and on individual behavior; the terms of governance and reporting; and V risk assessment, monitoring of indicators, and the control system. V The Committees all met at least once in 2019 and reviewed any Natixis places great importance on protecting clients’ interests and it regularly enhances its client information, KYC and complaint handling process. In terms of financial security , Natixis is determined to act with integrity and to fulfill its regulatory obligations regarding its fraud prevention, anti-corruption, anti-money laundering and Responsible Lobbying 6.2.3 In 2018, Natixis adopted the Charter for Responsible Lobbying and Advocacy Activities with respect to Governmental Bodies and Officials, which is 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 Combating tax avoidance 6.2.4 To combat tax avoidance, Natixis has control systems to ensure its transactions comply with tax laws and regulations. All new products and new activities 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. Natixis observes transparency rules intended to combat tax avoidance in France and around the world. It applies the Common

shortfalls with respect to the Code — in terms of Human Resources, risk, compliance or other matters — ensuring that these shortfalls were addressed in the annual appraisals of the employees concerned. All staff are required to complete mandatory training on the Code of Conduct. 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. A cheklist is available to help them do so.

Client protection, financial security and data security 6.2.2 Some ESR issues are identified and managed in the compliance risk prevention and management systems that fall under the Compliance Department’s responsibility.

counter-terrorist financing systems and to observe international sanctions and embargoes. To tackle cyber risk and ensure personal data protection , Natixis has a specific department that reports to the Compliance Department — the IT Systems Security and Business Continuity Department. For more information on these matters, see Chapter 3.2.8 “Compliance risk”.

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. 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 Persons. (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.

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NATIXIS UNIVERSAL REGISTRATION DOCUMENT 2019