BPCE_REGISTRATION_DOCUMENT_2017

6 SOCIAL, ENVIRONMENTAL AND SOCIETAL INFORMATION Sustainable and responsible value creation

Parent company and client company vigilance obligations BPCE is subjectto the Act of March 27, 2017 on the duty of vigilance, which calls for parent companies and client companies to prepare a vigilance action plan containingmeasures capable of identifyingand preventing risks of violating human rights and basic freedoms, the environment,and occupationalhealth and safety, associatedwith the activities conducted by BPCE as well as its subsidiaries, sub-contractors and suppliers. Mindful of the importance of these obligations, BPCE created a working group comprising experts from several divisions such as Sustainable Development,Risks, Compliance and Permanent Control, Human Resources, Procurement,and Legal, alongside representatives of Natixis, a BPCE subsidiary also subject to the law on the duty of vigilance. Tasked with identifyingthe main risks liable to arise in the course of conducting its activities, the working group selected the following two risk-mapping approaches: an approach tailored to the activities of BPCEand its subsidiaries; ● an approachspecificto the procurementfunction,developedduring ● the updateof procurement processes as awhole. The finalized vigilance plan will be disclosed in the registration documentfor fiscal year2018. Mapping approach tailored to the activities of BPCE and its subsidiaries In the course of its work, the working group identified the following main risks, recognizedby the 1789 Declarationof the Rights of Man and of the Citizen, the EnvironmentalCharter and, more broadly, by international law: in terms of human rights and basic freedoms: discrimination, ● violationof equality,the right to privacy and family life, freedomto protest,freedom of assembly, and freedom of opinion; in terms of personal health and safety: health-relatedrisk, failure ● to observe legal working conditions, forced labor, child labor, violation of worker safety and unequalaccess to healthcare; in terms of the environment:risk of pollution, adverse impacts on ● the fight against global warming or biodiversity, waste management. To this end, BPCE – a signatoryof the Global Compact(advancedlevel in 2017) – has undertaken to uphold the ten associated principles covering human rights, international labor standards, environmental protection and anti-corruption.The incorporationof these principles in the implementation of its “TEC 2020” strategic plan, corporate culture and business lines is a direct result of Groupe BPCE’s firm dedication, which it intends to report on each year in its Communication onProgress (COP). At the corporate and business line level, risks are identified and assessed, and initiatives undertaken to mitigate risks or prevent serious adverse impacts.

exercising vigilance when making contributions to political ● campaigns or to government agents, donations, patronage and sponsorship, and lobbying; supervising relations with intermediariesand business introducers ● via groupwide standardized contracts describing the reciprocal services and obligations and contractually establishing compensation terms. A whistleblowing system is available to employeesand included inthe Internal Rules. Employees also have access to a whistleblowing procedure. For the purposes of implementingthe Act of December 9, 2016 on transparency, prevention of corruption and economic modernization (“Sapin 2 Act”), Groupe BPCE has undertaken initiatives to analyze and expand existing measures. These initiatives include: group corruption risk exposures have been mapped out and ● distributed to all group institutions, based on an analysis of their activities and associated risk management systems; the Internal Rules adopted by each institutionare in the process of ● being amended with the employee representative bodies to incorporate the following changes: existingwhistleblowingsystemshave been extendedto reportsof - corruption or influence-peddling, and expanded to include provisionsto protect whistleblowers; codes of compliance or ethics now include, where applicable, - examplesof corruption and influence-peddling. The group has also defined standards and procedures governing KYC and due diligence procedures used for customer classification and supervisionpurposes.In the interestof organizingthe internalcontrol system, whistleblowing/detectiontools and permanent control plans serve to bolsterthe security of this system. BPCE also has accountingpoliciesand proceduresin place in line with professional standards. The purpose of the group’s internal control systemfor accountinginformationis to check the conditionsin which such informationis assessed, recorded, stored and made available, in particular by verifying the existence of the audit trail, within the meaning of the decree of November 3, 2014 on internal control. This control system is part of the fraud, corruptionand influence-peddling preventionand detectionplan. From a more general standpoint,these systemsare formalizedand detailedin the umbrellachartergoverning the organization of group internal control and the risk, compliance and permanent control charter. Parent company affiliates and all BPCE subsidiaries are required to adopt these charters, which are provided tothem expressly for this purpose. Finally, the group is examining ways to include examples of corruption in the regulatory e-learningmodule covering the rules of professionalethics distributed to employees of all group companies. Groupe BPCE takes part in the FBF’s initiatives aimed at formulating observations on draft recommendations submitted by the French anti-corruption agency. Meanwhile,Natixis is setting up an anti-corruptionprogram tailored to the specific featuresof its activities,while taking care to align this programwith Group BPCE guidelines.A descriptionof the program is available inthe Natixisregistration document.

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Registration document 2017