NATIXIS - Universal registration document and financial report 2019

6 NON-FINANCIAL PERFORMANCE REPORT

Managing environmental, social and governance risks

Duty of vigilance 6.4.2 The French law on the duty of vigilance requires Natixis to prepare, publish and implement a duty of vigilance action plan containing measures that can identify and prevent the risks of violating human rights and basic freedoms, harming the environment, and endangering occupational health and safety, that are associated with the activities conducted by Natixis as well as its subsidiaries, subcontractors and suppliers. Launched in 2017, the duty of vigilance project is overseen by Natixis’ ESR Department and involves several other departments: Purchasing, Human Resources, Logistics, Compliance and Legal. Several additional projects were initiated at the same time, with the aim of establishing a duty of vigilance plan for Natixis employees at its own offices, and also for its purchases of products and services. Work was also begun to expand the due diligence procedures implemented in respect of the bank’s financing activities. As such, particular attention is paid to climatic risks : physical and transition risks (see chapter 6.4.3) Lastly, Natixis’ Compliance Department has adapted the bank’s whistleblowing system to take new regulations into account (including, in particular, the duty of vigilance, but also the Sapin II law) (see Chapter 6.2.5) . Since 2017, Natixis’ Purchasing Department has joined forces with BPCE Procurement to create an economic interest group and share thoughts and ideas on responsible purchasing: The socially responsible purchasing policy is a source of strategic and operational leverage for implementing the BPCE and Natixis ESR policy. The main objective of the policy is to promote more eco-friendly products and services that provide guarantees and added value at the social and societal levels. Broader objectives are also pursued through this policy: assessing Natixis’ suppliers using social and environmental V responsibility criteria related to their products, services or industries; promoting official environmental certifications and eco-designed V products; encouraging suppliers to be more transparent in describing the V environmental characteristics of their products. In 2017, Natixis participated in a joint initiative involving several French Banking and Insurance companies and signed the Responsible Purchasing Charter. The aim of the charter is to encourage the suppliers of the signatory banks to implement duty of vigilance measures as part of their overall ESR approach. The charter sets a series of commitments that both parties are required to observe, based largely on the basic principles of the United Nations Global Compact in the areas of human rights, labor, the environment and anti-corruption (1) . Duty of vigilance in purchasing

Regarding the enforcement of the duty of vigilance law, Natixis and BPCE Procurement took part in a concerted effort in the banking and insurance sector to map out ESR risks in purchasing activities, involving three other banking groups. The map, which was delivered in June 2018, enables the following risks to be measured by country and by category of purchase: Fair practices and ethics Fraud and corruption Personal data protection Copyright and patents Environment Consumption of natural resources Pollution (air, water, ground) Biodiversity Carbon emissions Waste management Human rights It maps out risks by drawing on the expertise of the chosen supplier for each purchasing category, in addition to statistics on each country, in accordance with recognized standards. The mapping system identified 13 types of high ESR risk-type purchases from among more than 100 purchasing categories in the banking sector. These high risk purchases are to be the subject of targeted duty of vigilance measures: Under the new consultation procedures conducted by BPCE Procurement in sensitive categories, suppliers are assessed on the basis of their ESR performance: the ESR questionnaire based on the risk map is sent to the V supplier; the supplier must detail their action plan to deal with the identified V ESR risks; BPCE Procurement/Natixis ESR together assess this response; V the ESR grade is built into the supplier’s overall grade; V the supplier action plan must be implemented where ESR grade is V below average; monitoring of the supplier’s action plan. V A first set of suppliers in high risk purchasing categories (servers, ATMs, payment cards, furniture) has been assessed under the process applied since 2018 and other categories of suppliers are under assessment. This system can be used outside the consultation process for suppliers already approved or those that invoice large amounts to Groupe BPCE. BPCE Procurement has provided training to familiarize the procurement and ESR functions with the system, in the form of morning procurement meetings, classroom-based lessons and specific duty of vigilance e-learning courses. Health and safety Working conditions Discrimination Forced labor and modern-day slavery Child labor

https://back.bpce-achats.fr/storage/documents/9YMh2ecdXFSrAUhMOp4SKfZWh64bfInkxPnW5izi.pdf (French only) (1)

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NATIXIS UNIVERSAL REGISTRATION DOCUMENT 2019