BPCE_REGISTRATION_DOCUMENT_2017

SOCIAL, ENVIRONMENTAL AND SOCIETAL INFORMATION Sustainable and responsible value creation

6.3.3

Respecting business ethics in all Group business lines

PROMOTING AN ETHICAL CULTURE In accordance with its strategic plan, Groupe BPCE plans to implement a group Code of Conduct in early 2018, subject to validation by the Executive Management Committee and the Supervisory Board’sCooperativeand CSR Committee. The Code of Conduct willbe: divided into three parts: a message from Executive Management ● and principles of conduct, a business line approach for the definition of case studies (customer perspective, employer responsibility, societal responsibility), and validation and implementationacross allgroup institutions. Once published, all employees will receive training on the code, an ethical governance system will be established, ethics will be incorporated in HR processes, and the code will be aligned with internal procedures. The group already provides training on the “fundamentalsof ethics”, which willbe adapted accordingly. rooted ininternational values and standards; ● practical, with clear illustrative examples; ●

RESPONSIBLE COMPLIANCE APPROACH In accordance with internal control measures and the Group’s risk, compliance and permanent control charter, Groupe BPCE’s Risk, Compliance and Permanent Control division has set up several controls under its financial security and ethics and compliance frameworks. Prevention of money laundering and fraud Pursuant to regulations governing internal control of credit institutions and investment firms, Groupe BPCE institutions have establishedmethodsfor detectingunusualtransactionsin accordance with their risk classification.These methodscan be used, if necessary, to performa more extensiveanalysis and submit the required reports to Tracfin (French anti-money laundering and anti-fraud agency) as quickly as possible. The group’s risk classification system covers “high-risk” countries (listed by the FATF, the OECD World Forum on transparency and exchange of information for tax purposes, TransparencyInternational,the French Treasury for regions controlled by terrorist organizations, etc.). The Group Financial Security division keeps the institutions up to date on how to observe the restrictive measures imposed by international sanctions. Group institutions are provided with pre-selectiontools used to alert customers(freezing of assets owned by certain persons or entities) and internationalcapital flows (freezingof assets and countriessubject to Europeanand/or US embargoes).

TRAINING ➡

2017

Indicator

2016

2015

Percentage ofemployeestrained in theirentity’s anti-money launderingpolicies and procedures (1) (basedon reportsfrom the entities)

6

90%

88% (2)

98%

Numberof employees(on permanent,fixed-term,or work-studycontracts)who have receivedanti-moneylaunderingtraining in the last two years. (1) Percentagecalculatedbasedon two yearsof trainingactivityand for the averagenumberof permanentfull-timestaff.ExcludingBPCE SAgroupand CFF. (2)

In 2017, Groupe BPCE was not sanctioned for any anti-competitive, anti-trust or monopolistic behavior. Prevention of corruption Corruption, which is defined as an act in which a person offers or grants an undue reward to another person in exchange for an act falling within that person’s remit, is a fraudulent and unethical behavior subject tosevere criminaland administrative sanctions. Groupe BPCE denounces corruption in all forms and in all circumstances. Accordingly, it is a signatory of the United Nations Global Compact,whose tenth principlestates that “Businessesshould work against corruption in all its forms, including extortion and bribery.”

Anti-corruption measures The group strives to prevent corruption in order to guarantee the financial security of its activities, including inparticular: by taking measures against money laundering and terrorist ● financing, measures against fraud, supervising politically exposed persons, and complying with embargoes (see Chapter 3 of the registration document for more details); ensuring that employees observe professional rules of compliance ● and ethics by applying policies governing conflicts of interest, exchanges of gifts, benefits and invitations, confidentiality and professional secrecy. Disciplinary sanctions have been defined for any failure to comply with professional rules governing the activitiesconducted by group companies;

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Registration document 2017