BPCE_REGISTRATION_DOCUMENT_2017

SOCIAL, ENVIRONMENTAL AND SOCIETAL INFORMATION Sustainable and responsible value creation

To assess identified risks, the working group decided to analyze current conditionsat major Groupe BPCE entities, select priority risks and develop appropriate action plans. The procurementrisk mappingexercise,describedin detail below, also identifies other risks such as risks associated with the business climate and environment, including labor or business environment intensity, and risks associated with fairness of business practices, such as fraud and corruption, personal data protection, intellectual property rights and patents. When the mapping exercise is complete, BPCE plans to establish a whistleblowingand reporting system to determine if and how such risks materialize, and a system to monitor corrective measures in place and assesstheir effectiveness. Risk mapping specific to the procurement function In accordancewith the Act on the duty of vigilance, and in a bid to adopt a concerted approach in the bancassurance business, BPCE Procurement (for Groupe BPCE) and three other banking groups decided to map out their shared CSR risks by procurementcategory. In early 2018, the results of this joint effort will be used to identify risks of serious violations of human rights and basic freedoms, personalhealth and safety, and the environment,and to prioritizethe necessary actionsin each category. Depending on the level of risk determined by the risk mapping exercise, and based on the associated expenses, Groupe BPCE’s existing suppliers will be assessed for their CSR performance. The results of these assessments will be shared with the suppliers. Depending on the results, an improvement plan can be established with the supplier, subject to review at the six-month point. To get the vigilance plan up and running, the procurementmanagers will team up with their Head of CSR to develop a joint action plan. BPCE Procurementwill provide training to help the procurementand CSR functionsbecome familiarwith the new tools (risk mapping,CSR assessment, implementation of appropriate risk prevention or mitigationplans). Furthermore,an indicator will be defined to monitor the percentage of Requests for Proposals (RFPs) including a CSR assessment of biddingsuppliers.The calculationof the indicatorwill be based on the number of RFPs including a supplier CSR assessmentout of the total number of RFPs targeted in the vigilance plan. Another indicator will be used to keep track of the percentage of RFPs significantly incorporating CSR performance in the assessment of a supplier’s overall performance.

relevant regulatory requirements, in particular those intended to protect customer interests and personal data, are taken into account in a product’s design, promotional literature and terms of sale. The importanceof protectingcustomerinterestsand data has grownwith the development of digital services and applications in the banking and financial sector. The procedure draws on BPCE’s various areas of expertise (including in particular legal, finance, risk, information systems, compliance, taxation, security). Contributions from experts in these areas are presented to the Review and Validation Committee for New Groupe BPCE Products (CEVANOP), and each product or service must be approved before it can be brought to market. In order to streamline and secure the product and service validation process, while cutting down on paper volumes, a collaborativeworkflow tool was installed on BPCE’s information system in July 2017, called the CEVANOP platform. A similar procedurealso applies to the sales process,and in particular the remote selling process, as well as sales materialsused to promote products and services to theGroup’scustomers ona regular basis. The Group has not implemented a systematic CSR labeling scheme across all of its banking products. Products with major CSR implications,environmentalproducts and social and solidarity-based products belong to a separate range to make them easily identifiable for customers,includingMirova’srange of investmentfunds and SME finance funds, particularly for innovative SMEs (FIPs – local investment funds, FCPIs – innovation investment funds, see Section6.2.1 “Responsibleinvestment”). Transparency of product offer The group places great importance on keeping customers properly informed through branch displays and contractual, pre-contractual and commercial documents. Group institutions have been provided with a complianceguide listing all their associatedobligations.This is backed by the product governance procedure, ensuring that all commercial documents are validated beforehand by the Compliance and/or Legal division. To ensure that all employees fully understand the importanceof preventingthese risks, they are specially trained in banking law (customerprotection:banker’s duty to advise, protection against over-indebtedness, etc.), the right to hold an account, and vulnerablecustomers. 2017: investing in customer feedback 2017 was the last year of the “Another way to grow” strategic plan, which saw Groupe BPCE companies equipped with the most modern customer feedback mechanismson the market in a bid to effectively and efficientlymeet its customerexpectations. Group companies established spontaneous feedback systems in the individual,professionaland private bankingsegments,for the purpose of assessing the quality of customer relations based on customer interactions with advisors. As a result, over 500,000 customers are surveyed each month. Customer satisfaction and quality policy

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RESPONSIBLE MARKETING AND CUSTOMER PROTECTION

CSR analysis of new products and services

In September 2010, Groupe BPCE introduced an approval procedure for new banking and financial products and services aimed at customers of both networks. This procedure primarily aims to ensure that the risks associated with marketing products and services to customers are adequatelymanaged. It does this by ensuring that all

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Registration document 2017