2023 UNIVERSAL REGISTRATION DOCUMENT

AND ANNUAL FINANCIAL REPORT

Groupe BPCE, the second largest banking group in France, performs a full range of banking and insurance activities.

With over 100,000 employees, its serves 35 million customers worldwide including individuals, professionals, companies, investors and local authorities. It operates in the retail banking and insurance fields in France via its two major networks, Banque Populaire and Caisse d’Epargne, along with Banque Palatine.

It also pursues its activities worldwide with the asset & wealth management services provided by Natixis Investment Managers and the wholesale banking expertise of Natixis Corporate & Investment Banking.

www.groupebpce.com

This Universal Registration Document was filed on March 25, 2024 with the AMF, in its capacity as the competent authority in respect of Regulation (EU) No. 2017/1129, without prior approval pursuant to Article 9 of said regulation. The Universal Registration Document may only be used for the purposes of a public offering or admission of securities to trading on a regulated market if it is accompanied by a memorandum pertaining to the securities and, where applicable, an executive summary and all amendments made to the Universal Registration Document.

The complete package of documents is approved by the AMF in accordance with Regulation (EU) No. 2017/1129. Copies of this Universal Registration Document may be obtained free of charge from BPCE, 7, Promenade Germaine Sablon 75013 Paris.

The English version of this report is a free translation from the original which was prepared in French. All possible care has been taken to ensure that the translation is an accurate presentation of the original. However, in matters of interpretation, views or opinion expressed in the original language version of the document in French take precedence over the translation.

Only the French version of the Universal Registration Document has been submitted to the AMF. It is therefore the onlyversion that is binding in law.

Message from the
Chairman of the Management Board

Nicolas NAMIAS

Chairman of the Management Board of BPCE

Our Group strengthened its commercial momentum in 2023 while increasing its financial strength to bring it up to the highest standard in Europe. This result is all the more remarkable given that the activity of our business lines took place in a subdued economic context and a tense international environment.

Thanks to particularly strong commercial activity in all customer segments, the Banque Populaire and Caisse d’Epargne networks continued to expand their business, posting a gain of 925,000 new customers over the year, while the insurance, payments and specialized financing activities continued to grow. In the Global Financial Services, Corporate & Investment Banking recorded its highest level of annual revenue, and Asset Management maintained a solid performance in a challenging market for the industry.

As we had anticipated, Groupe BPCE’s financial performance was marked by the rapid rise in interest rates; this impact is commensurate with the place we occupy in the financing of the French economy. For the customers of the Banques Populaires and Caisses d’Epargne who hold loans, this fixed-rate financing model has made it possible to protect their purchasing power, in line with our cooperative values.

I would like to thank our 100,000 employees in France and abroad for their daily commitment alongside our customers. They contribute to making our Group a central player in the economy, at the heart of environmental, technological and societal issues.

The commercial development of our businesses and our solid fundamentals are key assets for our sustainable growth strategy. This is the ambition that drives us with all the Group’s executives as we define the new strategic project that will guide our action for the coming years.

“The commercial development of our business lines and our solid fundamentals are key assets for our sustainable growth strategy.

Groupe BPCE at a glance

A cooperative, multi-brand and entrepreneurial model serving its customers and the economy

Groupe BPCE is the second-leading banking group⁽¹⁾ in France and finances 22%⁽²⁾ of the French economy. All our customers, be they individuals, professionals, associations, corporate customers of all sizes or institutional customers, have constantly evolving expectations, with increasing demands in terms of availability, feedback, advice and service.

Our business lines, in France and internationally, offer solutions tailored to meet these needs, in retail banking, insurance, financial solutions & expertise, payments, asset & wealth management, and corporate & investment banking.

In the regions and internationally, our brands support, with short decision-making circuits, our customers in all their projects, through all distribution channels.

We are convinced that our universal cooperative banking model, successfully built around strong brands recognized and close to their customers, is a model of the future, deeply in line with the aspirations and needs of society. Multi-entrepreneurial and decentralized, it allows us to operate over the long term.

With strong positions in each of its business lines, our Group is able to accelerate its development by always providing better support to our customers in their projects. We intend to deploy the full potential of our model to be a leader in banking, insurance and asset management for all.

Diversified businesses, Strong, recognized brands

BPCE 2024 strategic plan and objectives

Three priorities and three key areas structure this three-year development plan.

Three strategic priorities

Five priority areas defined with a target for additional revenue of around €1.5 billion and acceleration of international development.

TWO GROWTH DRIVERS WITH SOCIETAL CHALLENGES

> Environmental transition

The Group intends to support all its customers in this market:

> Healthcare

Already a leader in the financing of public hospitals, Groupe BPCE intends to become the benchmark partner in the healthcare sector:

TWO KEY ACTIVITIES TO ACCELERATE, SOURCES OF VALUE CREATION

> Non-life insurance

As a fully-fledged bank-insurer, the Group will rely on its latest generation platform to develop, offer a differentiating customer/advisor experience, support network advisors in marketing and accelerate professional and individual health offers.

> Consumer loans

Thanks to the equipment potential of Banque Populaire and Caisses d’Epargne customers, Groupe BPCE wants to position itself as a leader in this market, with the launch of new solutions (instant personal loans, digital revolving credit, and debt restructuring), investments in digital technology and the development of online assistance.

A CUSTOMER MARKET TO BE DEVELOPED

> Medium-sized companies

Thanks to its regional roots and the complementary nature of its businesses, Groupe BPCE has set itself the goal of developing its customer base and its financing outstandings in the medium-sized segment.

INTERNATIONAL

> Speeding up the growth in the international arena of our global business lines

In Asset Management and in Corporate & Investment Banking, Groupe BPCE has confirmed the United States as the second main market after France and is accelerating its development in the Asia-Pacific region (APAC).

> Specialized financing

A growth strategy in Europe through development, from Oney, and acquisition opportunities in the consumer loans and leasing businesses.

The Group aims to offer its retail banking customers the best experience thanks to a “3D” relational model, with a pragmatic and local approach to the network of branches. All of the Group’s business lines and companies have set Net Promoter Score (NPS) targets for 2024.

3D RELATIONSHIP MODEL

> Trustworthy

The customer advisor, the linchpin of a long-term banking relationship of trust, supports the customer in all of their life events

> Digital Inside

100% accessible banking, omnichannel pathways and digital spaces for digital native players

> Useful data

Customization of the solutions provided and of the proposed pathways according to customer needs, automated data collection, management of consents

PRAGMATIC AND LOCAL APPROACH OF THE NETWORK OF BRANCHES

Groupe BPCE joined the Net-Zero Banking Alliance in 2021 and made concrete commitments to achieve carbon neutrality by 2050.

ALIGNING PORTFOLIOS WITH A NET ZERO TRAJECTORY 

SUPPORT FOR ALL CUSTOMERS IN THEIR ENVIRONMENTAL TRANSITION

EXTENSION OF THE SUSTAINABLE FUNDING STRATEGY

ACCELERATING THE REDUCTION OF THE GROUP’S OWN ENVIRONMENTAL FOOTPRINT

Three lines of force

A SIMPLER AND MORE LEGIBLE ORGANIZATION

EVOLUTION OF INFORMATION SYSTEMS

ACCELERATED TRANSFORMATION OF BANKING SERVICES

DATA AND NEW TECHNOLOGY MARKETS: CHANGING SCALE

PAYMENTS: ACCELERATING TO SUPPORT THE DIGITALIZATION OF RETAIL TRADE

DESIGNING THE FUTURE OF WORK

TIGHT ECONOMIC PERFORMANCE AND FINANCIAL STRENGTH, AT THE HEART OF THE AMBITIONS OF THE STRATEGIC PLAN

TIGHT RISK MANAGEMENT

CONFIRMED FUNCTION AS A TRUSTED THIRD PARTY

Targets of the BPCE 2024 strategic plan

Governance

Composition of the Supervisory Board

Supervisory Board members’ expertise^*

Management Board members

Business model

OUR PURPOSE: Resolutely cooperative, innovative and committed players, retail bankers and insurers,Groupe BPCE companies and employees support their cooperative shareholders and customers with financial solutions adapted to each one and build a sustainable and responsible relationship with them

A solid group generating robust performances

A recurring and diversified revenue base

Ratings as of December 31, 2023

KEY NON-FINANCIAL FIGURES

BPCE SA group indicators⁽¹⁾

SUMMARY INCOME STATEMENT

Groupe BPCE was established in 2009 through the merger of the Banque Populaire and Caisse d’Epargne groups. This marked the combination of two leading cooperative banks, created in 1878 and 1818 respectively, sharing common values rooted in solidarity, a local presence, democratic governance and a long-term vision.

The first step to forming the Group took place in 2006, with the creation of Natixis from the merger of Ixis and Natexis Banques Populaires.

In 2021, Natixis shares were delisted and the Group simplified its organization. It thereby strengthens its universal cooperative banking model.

True to its roots and history, Groupe BPCE supports the major changes of today, whether they be digital, environmental, or social.

BANQUE POPULAIRE

CAISSE D’EPARGNE

2006: THE BANQUE POPULAIRE AND CAISSE D’EPARGNE GROUPS
UNITE THEIR STRENGTHS BY CREATING A JOINT SUBSIDIARY, NATIXIS

The Banques Populaires and the Caisses d’Epargne are owned by 9.6 million cooperative shareholders. This highly stable shareholding structure is imbued with a strong cooperative spirit.

The 14 Banques Populaires and the 15 Caisses d’Epargne hold an equal 100% stake in BPCE, which is responsible for defining the Group’s policy and strategic orientations, and coordinating the commercial policies of each network.

The Banques Populaires and Caisses d’Epargne are banks in their own right. They collect deposits and savings, distribute loans and define their priorities locally.

The Fédération nationale des Banques Populaires (FNBP) and the Fédération nationale des Caisses d’Epargne (FNCE), the bodies that provide deliberation, communication and representation for the two networks and their cooperative shareholders, play an essential role in defining, coordinating and promoting the banks’ cooperative spirit and social responsibility initiatives, in accordance with Groupe BPCE’s commercial and financial objectives. Persons representative of their regional economies sit on the Board of Directors of the Banques Populaires and on the Steering and Supervisory Board of the Caisses d’Epargne. Their resources are first and foremost allocated to meet the needs of local areas and regional customers.

Group architecture

Under the cooperative banking model, cooperative shareholding customers are the focal point of the Group’s governance.

The Banques Populaires and Caisses d’Epargne are credit institutions wholly-owned by their cooperative shareholders (via LSCs – Local Savings Companies – for the Caisses d’Epargne).

Cooperative shareholding customers – both individuals and legal entities – play an active part in the life, ambitions and development of their bank.

Being a cooperative shareholder means owning a cooperative share (a percentage of the share capital not quoted on the stock exchange), representing a portion of the share capital in a Banque Populaire or an LSC for a Caisse d’Epargne, and playing a role in the bank’s operation by taking part in General Meetings and voting to approve the financial statements and resolutions, validating management decisions and electing directors.

Each institution is governed by a Board of Directors and a Chief Executive Officer for the Banques Populaires, or a Steering and Supervisory Board and a Management Board for the Caisses d’Epargne.

SEE CHAPTER 3

« CORPORATE GOVERNANCE »

BPCE brings together the central institution of Groupe BPCE, the retail and global business lines, as well as the resource pools.

The central institution is responsible for defining the policy and strategic orientations of the Group and each of the two networks.

The main duties of the central institution, as defined by the French act of June 18, 2009, are:

• coordinate trade policies;

• represent the Group and its networks, and negotiate national/international agreements on their behalf;

• represent the Group and its networks as an employer;

• take all necessary measures to ensure the Group’s liquidity and solvency, risk management and internal control.

All banks affiliated with the central institution are covered by a guarantee and solidarity mechanism.

Since November 2023, the retail and global business lines have been brought together under the umbrella of BPCE. This collective operates while respecting the legal structures, existing brands and specific characteristics of each business line. BPCE brings together the following activities:

• Insurance

• Digital & Payments

• Financial Solutions & Expertise

• Global Financial Services (i.e. global business lines)

• BPCE Technologies & Opérations

BPCE also includes Banque Palatine, Natixis Algérie and Crédit Foncier.

Groupe BPCE is made up of the two major cooperative networks, Banque Populaire and Caisse d’Epargne, as well as BPCE, the collective that brings together the central institution and its departments, and the retail and global business lines.

SEE CHAPTER 1

“THE GROUP’S BUSINESS LINES”

January

Following their alliance, Swile and Groupe BPCE created a new leader in employee benefits and worktech. Swile now owns 100% of Bimpli, and Groupe BPCE became Swile’s largest shareholder with a 22% stake.

Oney, a Groupe BPCE subsidiary specializing in innovative payment solutions and financial services, announced the signature of a cooperation agreement with Ingka Group, IKEA’s main distributor in Portugal, Belgium and the Netherlands. This agreement strengthens Oney’s leadership in Europe.

Banque Populaire strengthened its presence among innovative healthcare players by signing a partnership agreement with France Biotech, the leading independent French association of innovative healthcare entrepreneurs and their expert partners. In particular, this collaboration will bring new solutions to customers in the fields of e-health, medTech and bioTech.

February

Groupe BPCE became a shareholder of Scope Group, a financial and non-financial rating agency covering all asset classes (countries, companies, public authorities, financing, etc.). The aim is to support a European initiative in the rating market, which is dominated by the major Anglo-Saxon agencies.

March

The 15 Caisses d’Epargne launched their Utility Contract and deployed a new communications strategy to promote their commitments to “Be the most useful player alongside their customers in transforming society”. As regional cooperative banks, the Caisses d’Epargne are stepping up their action in support of regional development and transformation in three areas: the economy, the environment and social issues.

April

On the occasion of the Paris 2024 Olympic and Paralympic Games, BPCE became a major patron of Paris Musées and the leading patron of the Petit Palais. The venue will be fitted out to provide an unforgettable experience for over 20,000 guests, customers and teams. With this three-year partnership, Groupe BPCE is committed to three major initiatives. It will finance the restoration of the peristyle and its fresco. It will contribute to a new, responsible focus on the museum’s permanent collections, both its masterpieces and its sports-related works. Last but not least, it will support work to improve the Petit Palais’ energy performance.

The Group announced its participation in the financing of France’s fifth offshore wind farm, off the islands of Yeu and Noirmoutier. Construction will take two and a half years, and will directly employ 1,600 people. By 2025, the 62 wind turbines with a combined output of 496 MW will be able to supply nearly 800,000 people with renewable energy. More than 17 international banks are involved in the €2.5 billion financing package, including Groupe BPCE with Caisse d’Epargne Bretagne Pays de Loire, BPCE Energeco (a subsidiary of BPCE Lease), Natixis Investment Managers and Natixis Corporate & Investment Banking, and the Caisse d’Epargne fund dedicated to financing energy transition projects.

Natixis Corporate & Investment Banking inaugurated a branch in South Korea, to complement its product offering and customer base in the region.

May

Caisse d’Epargne accelerated its development in the wine market with the creation of Vitibanque. This comprehensive offering is built around an organization dedicated to winegrowers and a range of products and services tailored to their day-to-day needs. For its part, Natixis Interépargne launched the first customizable video guide to employee savings and retirement.

June

Groupe BPCE successfully carried out the first social bond issue in France dedicated exclusively to “Sport and Health” themes. The placement of this social bond, carried out by Natixis Corporate & Investment Banking teams, raised €500 million to refinance Sports and Health assets on behalf of the 14 Banques Populaires and 15 Caisses d’Epargne. With the launch of this issue, Groupe BPCE is part of the Agenda 2030 aimed at meeting the United Nations’ sustainable development Goal No. 3 “Health and Well-being”.

The Banques Populaires and Caisses d’Epargne, Official Sponsors of the Torch Relay and Premium Partners of the Paris 2024 Olympic and Paralympic Games, opened their recruitment campaign to select 900 future bearers of the Olympic Flame from among their customers, cooperative shareholders, employees and the general public. More than 55,000 people have volunteered.

July

Groupe BPCE mobilized to support Banques Populaires and Caisses d’Epargne customers affected by the damage caused by urban violence. Faced with this extraordinary situation, the Banques Populaires and the Caisses d’Epargne set up an emergency plan to help all affected customers. These measures concern all customers: individual and professional customers, particularly small retailers and craftsmen, and businesses.

With “Sport for Health & Collective Commitment”, under the patronage of Stéphane Diagana, Groupe BPCE set up a scheme to develop long-term physical activity and sports for employees in all Group companies. Beyond its positive impact, it is also a lever for attracting and retaining employees, and a support for diversity and gender equality policies.

This program is part of the legacy of the Premium Partnership with Paris 2024.

September

Banque Populaire, Fédération Nationale des Socama and the European Investment Fund (EIF) signed a new agreement to counter-guarantee loans of up to €1 billion under the InvestEU “Competitiveness of SMEs” program. In 20 years, the partnership with the EIF has enabled Banques Populaires and Socama to support 250,000 entrepreneurs with €9 billion in loans.

October

Banques Populaires and Caisses d’Epargne signed a partnership agreement with Papernest, a start-up specializing in simplifying the administrative procedures involved in household contracts and subscriptions. Against a backdrop of rising inflation and energy costs, Banques Populaires and Caisses d’Epargne helped their individual customers to improve their purchasing power by offering them comprehensive, free support in optimizing their gas, electricity, internet and cell phone subscriptions.

Banque Populaire expanded its range of services and launched Rythméo Start, an innovative, simple and digital banking solution to support all self-employed customers. Thanks to a fast, simple and secure online subscription process, the entrepreneur benefits from an adapted offer with all the essential services to get his or her business off to a good start.

Natixis Corporate & Investment Banking expanded its presence in North America by opening a representative office in Toronto. Natixis Wealth Management unveiled its new communication campaign around ‘What’s your next move?’.

November

Groupe BPCE launched the innovative Tap to Pay solution on iPhone to enable Banque Populaire, Caisse d’Epargne and Payplug customers to make contactless payments. Accessible via iPhone, it is perfectly suited to the needs of craftsmen, small retailers, mobile merchants and entrepreneurs, as it does not require investment in hardware or a payment terminal. Tap to Pay on iPhone also meets the needs of major retailers looking to digitalize their points of sale, while further optimizing the in-store shopping experience.

Several Groupe BPCE banks participated in the financing of Toulouse Blagnac Airport’s first sustainability loan, in line with its commitment to CSR. Natixis Corporate & Investment Banking, Caisse d’Epargne de Midi-Pyrénées and Banque Populaire Occitane are involved, along with three other banks, in this double-tranche financing for a total of €145 million, the margin of which is indexed to ESG criteria. Natixis Corporate & Investment Banking is also acting as ESG coordinator.

December

Banque Populaire and Caisse d’Epargne launched “Elan Avril 2024”, the first savings offer in France linked to an index that contributes positively to people’s health and well-being. This savings product, designed by Natixis Corporate & Investment Banking teams, is indexed to a “health and well-being” index, made up of 75 international companies whose products and services contribute positively to people’s health and well-being by improving their physical and psychological condition through health, nutrition and sport.

EPI (the European Payments Initiative) announced the successful completion of its first account-to-account instant payment transactions with wero, the instant payment solution developed by EPI. This milestone was reached thanks to a successful real-life test between customers of Sparkasse Elbe-Elster in Germany and Banque Populaire et Caisse d’Epargne (Groupe BPCE) in France.

Natixis Investment Managers acquired a stake in Ecofi, a subsidiary of Crédit Coopératif, a French expert in solidarity and sustainable investment.

1.4.1 Retail Banking and Insurance

Banques Populaires

The 14 Banques Populaires are shareholders in BPCE on an equal footing with the Caisses d’Epargne, and are fully-fledged banks owned by their cooperative shareholders. They form a first-rate banking network made up of 12 regional Banques Populaires and two national affinity banks: Casden Banque Populaire, the benchmark bank for the French public sector, and Crédit Coopératif, the bank for the social and solidarity economy.

The Banques Populaires are actively involved in local communities and remain true to their entrepreneurial roots, providing their individual, professional, association, corporate and institutional customers with a full range of financing, savings, insurance, payment and specialized financial services (such as private management, leasing and factoring).

The Banques Populaires are wholly-owned by their cooperative shareholders. The strength and durability of their cooperative model is based on balanced governance. Members are cooperative shareholders, co-owners of their bank’s capital, through the purchase of shares. They elect the directors, who are committed local personalities, at the General Meeting, reinforcing the local character of Banque Populaire institutions.

MEASURED AND RECOGNIZED COMMITMENTS

Each year, the Banques Populaires measure the cooperative and responsible actions they carry out in their regions, mainly in three areas: local proximity, entrepreneurial culture, and cooperative and sustainable commitment. These actions are evaluated in euros in the cooperative and societal footprint, a tool based on ISO 26000 (the international standard for CSR) which references all the voluntary, non-regulatory and non-commercial actions carried out by the 14 Banques Populaires.

The 15 Caisses d’Epargne are equal shareholders of BPCE with the Banques Populaires, and are fully-fledged regional cooperative banks. Committed to local community life, they offer their individual, professional, association, corporate, institutional and local authority customers a comprehensive range of financing, savings, private management, insurance, payment and specialized financial services (such as leasing and factoring). They make decisions and act locally, in a short circuit, and reinvest their customers’ savings where they live to finance useful projects close to home (schools, hospitals, associations, etc.).

As cooperative banks, the Caisse d’Epargne belong solely to their 4.4 million cooperative shareholders, who participate in the decisions of their bank, voting on resolutions at the General Meeting and electing their representatives, the 2,500 Directors, from among their peers. Cooperative shareholders and directors are brought together in the local savings companies (SLE), which hold part of the capital of a Caisse d’Epargne and constitute a local tier, reinforcing the regional anchoring, proximity and expression of the cooperative shareholders.

AT THE SERVICE OF LOCAL ECONOMIC, SOCIAL AND ENVIRONMENTAL DEVELOPMENT

The Caisses d’Epargne are the only banks to provide long-term support to all players in a given region: individual customers, businesses, professionals, social housing and social and solidarity economy players, institutions, local authorities and associations. As such, they have the capacity to create the synergies required for local development.

In 2023, the 15 Caisses d’Epargne launched their Utility Contract to strengthen their commitment to the regions, for the benefit of those who live there.

This contract comprises 16 commitments broken down into concrete actions to be:

Banque Palatine, a 100% subsidiary of Groupe BPCE, is mainly dedicated to mid-sized companies, executives and private banking. For more than 240 years, Banque Palatine has been working alongside entrepreneurs on both a professional and personal level. It provides them with a range of banking products (current accounts, real estate and personal loans, financial investments, financing solutions to meet environmental challenges) and insurance products. Its network is made up of 26 “Corporate and Private Banking” branches and four “Banque Palatine Premium” remote branches offering all the remote banking services to meet their specific needs.

Banque Palatine offers value-added expertise dedicated to supporting its customers’ growth and performance: wealth, legal and tax engineering, investment advice, global approach to managers’ assets, corporate finance, specialized approach to real estate, trade finance, client desk, etc. In the regulated real estate market, where the Bank is the market leader, and in the audiovisual market, where it is a key player, it deploys a dedicated national organization.

Its signature “The art of being a banker” illustrates Banque Palatine’s determination to develop a model of close relationships based on excellent support for its 13,000 corporate and 48,000 private customers.

Banque Palatine is a patron of the French Sports Foundation. Through this sponsorship, Banque Palatine finances the training, socio-professional integration and retraining of four top sportsmen and women.

In 2023, business was brisk in both the Private Banking and Premium branch networks. The number of new private customers exceeded 990. Distribution of real estate loans amounted to almost €620 million.

The drive to win over companies with revenues in excess of €15 million continued, with 328 new customers active in this segment. The teams also won 377 new private customers, executives and senior managers among our corporate customers.

In 2023, Banque Palatine enhanced its range of products and services. Palatine Asset Management marketed two “buy and hold” collective investment products to private customers, which involve buying bonds with the aim of holding them to maturity. A dedicated portal was opened for property administrators, enabling them to open new condominium accounts in selfcare.

As a partner in the environmental transition of its ISE customers, Banque Palatine took a number of initiatives in the field of CSR, including: the marketing of BPCE green loans to complement its range of impact-based structured loans; the launch of the first “copro loan”, designed to finance co-owners in the context of energy and other renovation work; the raising of awareness among over 200 employees through the climate fresco; and the deployment of ESG questionnaires.

Lastly, the year was marked by the acceleration of Palatine Asset Management’s transformation around the first listing in the Group of its Article 9 Palatine Europe Sustainable Employment fund, which can now be marketed by Banques Populaires and Caisses d’Epargne to their customers.

Oney

A subsidiary of Groupe BPCE (50.1%) and Auchan Holding (49.9%), Oney is a French bank with an international dimension, expert in payment, financing and insurance solutions. Founded in 1983, Oney supports the daily lives of over seven million customers in more than 10 European countries. As a player in new consumer trends, it offers its customers solutions for financing their consumption through simple, secure purchasing paths, both in-store and online. Today, Oney is the leader in three or four split payment in France. Through its subsidiary Oneytrust, it is also a leader in fraud detection and digital identification.

In 2023, Oney’s sales momentum varied from one market to another, impacted by an unfavorable external context linked to rising inflation (which constrained household consumption and budgets) and rising refinancing rates. All players in the consumer finance sector have been affected by this environment, especially fintechs, for whom access to liquidity has become more difficult.

Oney recorded a +3% increase in new split loans, confirming its leadership with a market share of over 30% in France (Source ASF). Today, one in three split payments in France is made with Oney. This result is the fruit of a development strategy (17,000 sites and stores now use Oney solutions), illustrated in particular by the signing of new partnerships with Parc Astérix (leisure/Compagnie des Alpes Group), Canyon (sports) and Ovoyages (travel). Commercial synergies with the Caisses d’Epargne, Banques Populaires and Payplug were developed in the small business segment, in support of the 3x 4x split payment offer. In 2023, over 8,000 independent businesses in France used this payment service. In total, 7.2 million customers have used Oney’s services for their purchases and projects.

The expansion of the retail offering continued, with the roll-out of 5x to 12x split payment by bankcard. More broadly, Oney confirmed its expertise in consumer loans, with, for example, the signing of a European partnership with Ikea for a range of financing cards and long-term credit, as well as split payments. The roll-out of this partnership began in Portugal and in Belgium in 2023.

In full consultation with its two shareholders (BPCE and ELO, formerly Auchan Holding), Oney launched a transformation plan at the beginning of the year, with the aim of returning to profitability by 2024. In the final quarter of 2023, shareholders approved a 2024 -2027 strategic development plan positioning Oney as one of Europe’s leading consumer finance companies serving the retail sector.

BPCE Assurances

BPCE Assurances is Groupe BPCE’s Insurance division. A fully-fledged insurer, it designs, distributes and manages a comprehensive range of personal and non-life insurance products for customers of Groupe BPCE’s banking networks:

BPCE Assurances’ insurance subsidiaries (BPCE Assurances IARD, BPCE IARD, BPCE Vie, BPCE Life) do not distribute their products. The Group’s banking networks distribute their insurance products⁽¹⁾.

Personal insurance business was buoyant in 2023.

BPCE Vie confirmed its vitality in savings and pensions, with gross inflows up 16% to €12.95 billion. Net inflows of €5.5 billion were 17.7% higher year-on-year.

In personal protection insurance, sales momentum was driven in particular by funeral insurance in the retail market and by the Key Man contract in the professional market.

In borrower’s insurance (ADE), business held firm despite a significant reduction in the number of real estate loans granted, following the substantial rate hikes decided by the European Central Bank and passed on by commercial banks. ADE’s business was also constrained by the application of the Lemoine act, which came into force in 2022.

The year was marked by the opening of a new regional site dedicated to the personal insurance business in the metropolis of Rennes (Saint-Grégoire, Ille-et-Vilaine), bringing together all the company’s activities, with the exception of the customer relations centers, which remain located in Lille, Reims and Paris. This site will create 150 jobs in the region over the next five years.

Finally, BPCE Assurances confirmed its status as a pioneer insurer in terms of climate commitment. Each year, 10% of investments are dedicated to green assets so that they represent 10% of outstandings by 2030 at the latest. In 2023, 51.8% of its investments included a green criterion, going beyond the target. The share of its green outstandings rose to 12.6% of total outstandings, an increase of 5.1 points in one year. Lastly, the proportion of SRI-certified funds offered to BPCE Vie customers now stands at 61%, with a target of 60% by 2024.

Non-life insurance business was buoyant in 2023, with over 7.23 million contracts in the portfolio, up by almost 3%. Service quality remained high and continued to improve, with an annual NPS of 68 for the Customer Reception and Relations Platform and 41 for the Compensation activity.

Against a backdrop marked by a significant decline in new real estate loans, BPCE Assurances Non Vie managed to increase gross sales by 3%, driven by the motor business, and to maintain sales of home insurance contracts in particular.

BPCE Assurances IARD was there for its customers in the aftermath of both the urban violence in June and the multiple severe storms in November, which caused extensive damage.

The year was punctuated by the marketing of BPCE Assurances IARD products throughout the Crédit Coopératif network, enabling this institution to broaden its range of products and services for its customers, following the example of all the Banques Populaires.

Pursuing its policy of regionalization, BPCE Assurances IARD set up new claims teams at its Lens site.

Acting as a responsible insurer, BPCE Assurances IARD has a rate of 28.3% for the use of re-used or repaired parts. In addition, BPCE Assurances IARD has decided to place prevention at the heart of its strategy. For the third year running, it published its two-wheeler barometer of motorized two-wheeler users, conducted by Harris Interactive. The aim: to understand drivers’ behavior on the road and their relationship with safety, while identifying their expectations in terms of prevention.

In particular, to reinforce the security of its insured customers, BPCE Assurances IARD offered a one-year subscription to the “Liberty Rider” service. The app, which claims 1 million downloads since its launch in 2016, offers a host of features to make travel safer. Already available to the Banque Populaire network, it has now been extended to Caisse d’Epargne 2-Wheeler customers.

The Digital & Payments division

The Digital & Payments division brings together all of Groupe BPCE’s business lines and expertise in the fields of innovation, digital, data and artificial intelligence, payments, and trade finance with Oney. The division’s extensive expertise contribute to making Groupe BPCE the benchmark banking group in the digitalization of payments and customer experience:

The Financial Solutions & Expertise division

The Financial Solutions & Expertise (FSE) division brings together BPCE’s expertise in financing, insurance, custodial and advisory services for the Group’s corporate customers.

The entities that make up FSE are:

FOR THE FINANCING BUSINESS LINES

BPCE Financement develops offers and complete solutions for the management of revolving loans and personal loans for Groupe BPCE’s networks.

BPCE Lease offers a complete range of rental solutions: equipment and real estate leasing, trust, long-term vehicle leasing, leasing with purchase option, boating or automotive leasing, IT operational leasing, and renewable energy financing.

BPCE Factor develops factoring solutions to finance, manage and secure trade receivables for professionals and companies of all sizes.

SOCFIM is a leading player in the real estate financing market, covering the whole of France and all asset classes: new and existing housing, managed housing (students and seniors), offices, retail and logistics warehouses.

FOR THE INSURANCE BUSINESS LINES

Compagnie Européenne de Garanties et Cautions (CEGC) specializes in sureties and financial guarantees. CEGC offers a wide range of products and services across all the Group’s markets: individual customers, professionals and businesses, real estate, social economy and social housing.

FOR THE CUSTODIAL AND ADVISORY BUSINESS LINES

BPCE Solutions immobilières is a major player in real estate consulting in France. It comprises three business line divisions: Expertise & Consulting, Residential, Investment & Rental.

EuroTitres develops a comprehensive range of services for the custody of securities accounts and the management of transactions carried out by individual customers: stock market, mutual funds, securities transactions, portfolio statements, tax forms, etc.

Pramex International specializes in advising French start-ups, SMEs and ISEs on international expansion, either through internal growth (creating and overseeing foreign subsidiaries) or external growth (international acquisitions).

1.4.2 Global Financial Services

Global Financial Services (GFS) combines Groupe BPCE’s global business lines: Asset & Wealth Management and Corporate & Investment Banking. They serve corporates, investors, financial institutions, financial sponsors, as well as customers of the Banque Populaire and Caisse d’Epargne networks in the realization of their projects throughout the world. They offer them innovative and sustainable financing and investment solutions that contribute to the implementation of their environmental, technological and societal transitions.

ASSET & WEALTH MANAGEMENT

Asset & Wealth Management develops solutions to meet the deposits and savings, investment, risk management and advisory needs of the various private banking and institutional customers of Groupe BPCE.

Asset Management

Natixis Investment Managers (Natixis IM) is one of the world’s leading asset managers, and Europe’s second largest, with €1,166 billion in assets under management at the end of December 2023. Natixis IM supports investors on every continent in building their portfolios, offering them a wide range of diversified, responsible solutions.

With its decentralized and entrepreneurial multi-affiliate model, Natixis IM brings together the expertise of more than 15 specialized asset management companies and offers its investor customers a range of over 200 strategies to help them achieve their investment objectives, whatever the market conditions.

Managed from its headquarters in Boston and Paris, the company develops its offer around four key areas of expertise:

It deploys its offer through an integrated distribution network established in over 20 countries, in addition to the sales teams of the Banques Populaires and Caisses d’Epargne.

Wealth management

Established in France and Luxembourg, Natixis Wealth Management designs and implements tailor-made wealth management and financial solutions to structure and manage the assets of business leaders, senior executives, large private investors and holders of a family capital. It supports them in their initiatives to undertake, invest and transmit, and mobilizes a wide range of expertise that covers all their needs, whatever the size or maturity of their projects: corporate advisory, origination, vanilla and complex financing, investment, portfolio engineering, asset management and diversification solutions, particularly in private equity.

The entire value proposition is tailored to the degree of personalization desired by the customers and is distributed via two channels: BtoC and BtoB. To expand its range of products and services in listed and unlisted asset management, Natixis Wealth Management draws on the complementary expertise of its three subsidiaries: Vega Investment Managers, in collective asset management, delegated management and open-architecture fund selection; Massena Partners, dedicated to advising private family groups and family offices, mainly in private equity; Teora by Natixis Wealth Management, specialized in high-end, open-architecture life insurance brokerage.

Employee and pensions savings

Natixis Interépargne, a leader in employee and pensions savings, is invested in the future of over 90,000 corporate customers⁽¹⁾ and in the service of more than 3.2 million savers⁽¹⁾. A pioneer in innovation for over 50 years, it helps companies of all sizes to set up and manage their employee savings and retirement schemes (PEE, PERCO, PER Collectif, PER Obligatoire), as well as their employee share ownership schemes, to make them a performance driver. It offers them a unique, high-performance management offering to help them achieve their savings objectives. Natixis Interépargne draws on the wealth and diversity of expertise of more than 15 management companies affiliated to Natixis Investment Managers. With over €35 billion in assets under management⁽¹⁾, it is a leader in SRI and solidarity-based asset management, with a 20.3%⁽²⁾ market share in SRI employee and pensions savings, and a 21.1%⁽²⁾ market share in solidarity-based employee savings.

CORPORATE & INVESTMENT BANKING

Natixis Corporate & Investment Banking (CIB) supports its corporate customers, financial institutions, institutional investors, financial sponsors, public sector entities and the Groupe BPCE networks. It advises them and designs innovative, tailor-made solutions to support their strategy, drawing on the full range of its expertise in advisory services, investments, financing, commercial banking and capital markets, as well as its global presence in nearly 30 countries across three geographic zones: North & South America, Asia-Pacific and EMEA.

Natixis CIB is organized around five main business lines (Global Markets, Investment Banking, Real Assets, Global Trade, M&A):

The Global Markets business line offers a wide range of hedging, financing and investment solutions on the fixed-income, credit, foreign exchange, commodities and equity markets, combined with recognized economic research.

The Investment Banking teams support their customers in their strategic decisions: acquisitions, asset sales or purchases and, more generally, any growth project. Offering high value-added solutions, Investment Banking encompasses strategic and acquisition financing, financing on the primary bond and equity markets, and financial engineering for listed holdings.

The Real Assets business line combines the origination and structuring of structured finance in the sectors of Aviation, Infrastructure & Energy and Real Estate & Hospitality. Real Assets relies on a global network of experts in 10 offices around the world, and is recognized as one of the market leaders in these sectors.

The Global Trade business line includes the international trade financing activities, structured financing solutions for export transactions and cash management for its corporate customers, commodity traders and for customers of the Banques Populaire and Caisse d’Epargne networks. This business line, at the heart of the Group’s strategy, aims to support and finance the commercial development of its customers in a sustainable manner.

Finally, the teams specialized in mergers and acquisitions (M&A) support large- and medium-sized commercial and industrial companies, institutional investors and investment funds in the preparation and implementation of divestments, mergers, fundraising, restructuring or capital protection. This expertise is based on a network of seven stores in eight countries: Natixis Partners, Solomon Partners, Fenchurch, Natixis Partners Iberia, Vermilion, Azure Capital and Clipperton.

Natixis CIB’s core business lines are supported by a number of cross-functional teams, including the Advisory & Coverage division dedicated to customer support, which brings together bankers, sector experts and teams in charge of supporting customers’ environmental and technological transitions. To ensure a close relationship with customers, this division has a strong regional presence in France, and draws on all the bank’s teams of experts abroad.

The portfolio management teams support all financing activities and are central to the successful deployment of the bank’s Originate-to-Distribute model.

Lastly, in addition to its five main business lines, Natixis CIB is positioned, via its subsidiary Coficiné, as a leader in specialized financing for the media, entertainment and cultural industries.

https://groupebpce.com/

“Investor Relations” section

François Courtois,

Director of Financial and Non-Financial Communication, Investor Relations, ST credit facility sales and Branches

Achievements for the environmental transition

Alignment of the trajectory of our financing and investment portfolios with the objective of carbon neutrality in 2050

Supporting our customers in their environmental transition challenges

With awards for Natixis CIB in sustainable finance

(1) Transition projects for customers of the BP and CE networks (energy renovation of homes, green mobility, renewable energies and other projects).

Achievements serving the sustainable, economic and societal development of our regions

(1) Olympic and Paralympic Games Committee.

A model in line with the aspirations and needs of society

A SOLID COOPERATIVE MODEL THAT FAVORS THE LONG TERM

Groupe BPCE is a cooperative full-service bank and insurance Group serving its 35 million customers, cooperative shareholders, regions and the economy. It has two main business lines: Retail Banking and Insurance in France, Asset & Wealth management and Corporate & Investment Banking worldwide.

The strength and durability of our model are based on balanced governance. Cooperative shareholders hold 100% of the share capital of the 14 Banques Populaires and the 15 Caisses d’Epargne through cooperative shares. The 9.6 million cooperative shareholders elect representatives who make up the members of their Boards of Directors and Steering and Supervisory Boards. The Banques Populaires and the Caisses d’Epargne hold 100% of the capital of BPCE, the Group’s central institution.

Our cooperative, multi-brand and entrepreneurial dimension is our identity; it allows us to be closely aligned with customers’ expectations and society’s aspirations. Our decentralized model and our regional roots are real assets for driving transitions and sustainably transforming society: our companies act locally, as close as possible to our customers, providing innovative solutions in response to the challenges of our time.

By focusing its strategy and actions on the long term, our Group is able to reconcile economic performance, social equity and environmental protection.

IN GROUPE BPCE’S DNA: SUSTAINABLY SUPPORTING ECONOMIC AND SOCIETAL CHANGES

The nature of our activity and our outreach give us a great responsibility in the face of societal and environmental challenges, foremost among them the fight against climate change.

Extreme climate events are multiplying, and 2023 was a record year for global temperatures. Global warming poses risks to the economy and could ultimately jeopardize its financial stability. The climate transition is an imperative for all of us, in a difficult economic and political context: persistent inflation, rising interest rates, growing social inequalities, high geopolitical tensions around the world, etc.

The societal and environmental challenges we face are shaking up our society and creating risks for our customers: increased exposure for the most vulnerable and those who will not be able to adapt, physical risks affecting the value of properties, increased costs (particularly those linked to energy renovation work), reputational risk, etc. These risks could lead to an increase in defaults and generate financial losses for our customers and therefore for the Group.

The transition to a low-carbon economy requires considerable levels of investment, funding and support for all economic players in their own transition. Our Group has made climate change one of the priorities of its BPCE 2024 strategic plan: our companies have all strengthened their systems to support the transition of their different customer categories, and climate issues are now inseparable from the activity of our business lines. It is both a development opportunity for our activities and a tremendous lever for the transformation of our business lines.

These profound transformations must not be carried out at the expense of the most vulnerable or future generations. As a leading player in the field of banking inclusion, whether in terms of preventing over-indebtedness or supporting microentrepreneurs, Groupe BPCE is also the leading banking player alongside protected persons, vulnerable individuals and companies in difficulty.

The Group’s social and societal commitment also extends to its 100,000 employees, through numerous initiatives in all regions: promotion of gender balance, diversity, inclusion, job retention of disabled and sick people, well-being at work and integration of young people, some of whom are from disadvantaged neighborhoods.

The Group is mobilized to put all its capacity for action at the service of its cooperative shareholders, its customers and, more broadly, society.

The business model is presented in the introduction of the 2023 universal registration document.

Groupe BPCE’s ESG strategy is structured around three areas, broken down into twelve commitments:

As a responsible bank and company, the Group places professional ethics at the heart of its operating model. The Group is committed to managing legal, regulatory and ethical risks for the benefit of its customers, employees and partners. Groupe BPCE thus ensures strict compliance with laws, regulations and best professional practices in all its companies. This is reflected in particular in a Group Code of Conduct and Ethics Standards approved by the Supervisory Board in 2018 and a rigorous tax policy with a Tax Code of Conduct approved in 2021.

OUR COMMITMENTS ARE MEASURED BY KEY PERFORMANCE INDICATORS

Launched by the United Nations, the sustainable development Goals (SDGs), a common language based on 17 goals broken down into 169 targets, have become the benchmark for measuring the progress made by governments and private companies. Groupe BPCE strives to fully integrate these objectives into its business lines or its own operations and contributes directly to the SDGs through the concrete actions described in each section of this Chapter.

The table below illustrates the link between the SDGs and Groupe BPCE’s 12 CSR priorities. This dashboard is used to manage the Group’s ESG strategy and provides our stakeholders with quantified and transparent information on our non-financial performance.

PUBLIC COMMITMENTS THAT MEET DEMANDING INTERNATIONAL STANDARDS

Groupe BPCE has made several long-standing commitments to scale up its actions and accelerate the positive transformations to which it is contributing.

PARTICIPATION IN SECTORAL WORKING GROUPS AND LOBBYING

As a cooperative bank committed to serving its cooperative shareholder customers, in the very heart of the regions, Groupe BPCE’s establishments intend to make a constructive contribution to the public debate by providing decision-makers and civil society with information on socio-economic changes at the regional, national or international level, as well as in the banking sector and its developments.

Groupe BPCE’s objective is to actively contribute to the reflection and to participate as a stakeholder in collective, fair and informed decision-making. Groupe BPCE’s lobbying initiatives are therefore strictly within this framework. In terms of lobbying, in addition to respecting its ethical rules and its cooperative values, BPCE applies all the regulations in force, as well as all the codes of ethics to which its public contacts, and the various financial market associations of which it is a member, are subject.

In 2023, a number of legislative texts impacting the Group’s business were monitored by Public Affairs, which took part in various working groups, responded to certain European public consultations and drew up Group positions. On certain specific subjects, Public Affairs requested meetings with members of the French Parliament, the French administration, ministerial cabinets and the various European institutions, either bilaterally or through certain professional associations.

Market positions are mainly held by trade associations. Groupe BPCE is a member of the following associations, among others: French Banking Federation (FBF) in association with the European Banking Federation (EBF), French Association of Banks and Investment Firms (AFECEI); French Banking Association (AFB); French Financial Management Association (AFG); Paris Europlace; Sustainable Finance Institute (IFD); France Assureurs; European Savings Banks Group (ESBG); European Association of Cooperative Banks (EACB); Institute of International Finance (IIF).

AT NATIONAL LEVEL

The main French texts on which Groupe BPCE has mobilized its teams are as follows:

As part of its work within the working Group of the Climate Commission of the French Banking Federation (FBF), chaired by the Chairman of the Management Board of Groupe BPCE, the Group participates in dialogues and discussions on:

AT EUROPEAN LEVEL

The main European texts on which Groupe BPCE has mobilized its teams are as follows:

Natixis’ Green Sustainable Hub (GSH) is also a very active contributor to various professional associations and authorities.

Groupe BPCE, convinced of the fundamental importance of the economy’s energy transition, is committed to the Institut de la Finance Durable (IFD), the French Sustainable Finance Institute created in January 2023. The Chairman of Groupe BPCE’s Management Board has joined the Board of Directors of the IFD, whose mission is to accelerate the Paris financial center’s action to achieve the environmental energy transition, resulting from the transformation of Finance for Tomorrow, the branch of Paris Europlace.

LOBBYING

BPCE is declared as a lobbyist on the register of the Haute Autorité pour la Transparence de la Vie Publique (French High Authority for the Transparency of Public Life – HATVP) and complies with the obligations of act No. 2016-1691 of December 9, 2016, on transparency, combating corruption and modernizing economic life (known as the Sapin 2 Law). Groupe BPCE complies with the recommendations issued by the HATVP on the relations of lobbyists with players in public life (https://www.hatvp.fr/fiche-organisation/?organisation=493455042.

Furthermore, when a voluntary register is set up by a parliamentary assembly or a national, European or international institution, Groupe BPCE representatives comply with the rules of ethics, access and circulation laid down by this register. Likewise, they respect the internal rules of representative assemblies and national, European and international institutions where they exist.

At the European level, Groupe BPCE is also listed in the European Commission transparency register. For the record, this register is a database listing the organizations that make their views known in the process of drafting legislation and implementing the policies of the EU institutions https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do?id=179370613236-62&locale=en#en

Groupe BPCE intends to participate in the development of all regions. The cooperative nature of the Group is one determining factor in how it conducts its business. The Group wants to help build an environment in which its cooperative shareholders and customers can grow.

Our regional banks have strong community ties, so they are attentive to the needs of all customers. They work with local players, local authorities, associations, business networks, schools and universities to strengthen the local socioeconomic fabric.

Each of the networks, Banque Populaire and Caisse d’Epargne, is backed by a federation. They support the network’s CSR strategy, facilitate cooperative shareholder relations, provide training for directors and assist with governance. They also promote initiatives in local communities.

BANQUES POPULAIRES

“Resolutely cooperative and innovative, Banque Populaire closely supports all those who live and work in each region over the long-term.” This is Banque Populaire’s overall purpose, defined in 2019.

Several regional banks have adapted this purpose to their regional specificities while keeping a common meaning, specific to the Banques Populaires. Three main areas of commitment have been defined, characteristic of Banque Populaire’s specificity: regional proximity, entrepreneurial culture, and cooperative and sustainable commitment.

The 5.2 million cooperative shareholders who hold the share capital of Banques Populaires are the bedrock of the cooperative model. They vote at General Meetings and directly elect the directors who represent them on the Boards of Directors.

For the General Meetings, the banks have given their cooperative shareholders the option of attending either remotely or by viewing the recorded proceedings. More than 597,000 cooperative shareholders voted in 2023.

For the past six years, the Banques Populaires have been organizing the “Faites de la coopération,” a week of awareness and discussion around the cooperative model, which is part of Social and Solidarity Economy (SSE) month. The 2023 edition highlighted the shared values of sport and cooperation. The program included a teaser video, quizzes for employees and cooperative shareholders, a concert on the theme of sports, a web conference and more.

In 2023, the Banque Populaire network had 244 directors (including the non-voting directors). They are business leaders, researchers, teachers and employees involved in the economic life of their region.

To meet the regulatory requirements for training directors and assessing how the Boards of Directors function, the National Federation of Banques Populaires (FNBP) has drawn up:

COOPERATIVE INDICATORS: COOPERATIVE SHAREHOLDER BASE AT DECEMBER 31

COOPERATIVE INDICATORS: GOVERNANCE AND DIRECTOR TRAINING

CAISSES D’EPARGNE

The 2022-2024 CSR & cooperative guidelines constitute the Caisses d’Epargne’s roadmap; several objectives have been set as part of the “Active cooperation” ambition, including a goal to rebalance the age pyramid of cooperative shareholders and the promotion of membership among employees.

The Caisses d’Epargne had a membership of 4.4 million cooperative shareholders at the end of 2023, the vast majority of whom were private individuals, spread across 179 local savings companies (SLEs), which constitute an intermediate level to strengthen local roots, proximity and the expression of cooperative shareholders.

In 2023, the Caisses d’Epargne continued and developed their efforts to get their cooperative shareholders even more involved in the life of their bank as key stakeholders. The 2022-2024 CSR and cooperative guidelines have strengthened the Caisses d’Epargne’s ambition in terms of cooperative shareholding. The goal is to increase the number of cooperative shareholders among customers and to offer them privileged access to information and offers from the members’ club via the unique portal https://www.societaires.caisse-epargne.fr/. In its region, each of the 15 Caisses d’Epargne implements promotional and communication initiatives designed to strengthen its relationship with its cooperative shareholders.

Some Caisses d’Epargne have also introduced initiatives to raise employee awareness of the cooperative model, notably during induction days for new recruits or during weeks dedicated to cooperative shareholders, in order to strengthen and rejuvenate the cooperative shareholder base.

Fédération Nationale des Caisses d’Epargne (FNCE), in consultation with the Caisses d’Epargne, conducted a study aimed at giving the Caisse d’Epargne cooperative model a simple, unique and differentiating definition: a Caisse d’Epargne is “a bank-insurance institution that is 100% regional, a pioneer in the transitions taking place in society, and one that belongs to its customer-cooperative shareholders.” For more information: www.federation.caisse-epargne.fr.

As part of the cooperative governance of the Caisse d’Epargne network, the Fédération Nationale des Caisses d’Epargne, in conjunction with BPCE and the Caisses d’Epargne, supports and trains elected representatives in the performance of their mandate through a dedicated training system. Training programs are designed for directors of local savings companies, members of the Steering and Supervisory Boards (SSB), and members of specialized committees. Each audience benefits from a training offer adapted to their mandate in a face-to-face format and/or by videoconference:

A distance learning system completes the system with a wide choice of online training courses, videos, quizzes and thematic sheets.

In 2023, the FNCE developed themes related to the ECB, cryptocurrency, combating money laundering and the financing of terrorism, and has deepened its module on climate risks.

Scenario workshops are also offered to enable members of the COS (Steering and Supervisory Board) to practice good governance of a Caisse d’Epargne and to encourage them to adopt a questioning method.

COOPERATIVE INDICATORS: COOPERATIVE SHAREHOLDER BASE AT DECEMBER 31

COOPERATIVE INDICATORS: GOVERNANCE AND DIRECTOR TRAINING

COOPERATIVE REVIEW

The French act of September 10, 1947, on the status of cooperatives establishes the principle of a cooperative review every five years. The review is performed by an independent auditor responsible for verifying that the structure and operation of cooperative entities observe cooperative principles and rules. Over the past three years, all Banques Populaires and Caisses d’Epargne have carried out a cooperative review. None of the Banques Populaires or the Caisses d’Epargne was identified as possibly being “non-compliant” with the cooperative banking model and the auditors voiced no reservations in the course of their audit.

Fighting climate change and creating a more low-carbon society is a major challenge of our time. In response, the financial sector has a key role to play by supporting the transition to a low-carbon economy, which balances the environmental, social and economic needs of society.

At the heart of its concerns, the environmental transition is one of the three pillars of the BPCE 2024 strategic plan and is a priority for all its business lines and all its companies.

Groupe BPCE has set itself four major objectives:

GOVERNANCE DEDICATED TO CLIMATE RISKS

In order to manage these climate-related commitments as closely as possible, the Group has strengthened its governance bodies (see Section 2.1.2) and the management of climate-related risks.

The Climate Risk division was created on January 1, 2019, within Groupe BPCE’s Risk division. In 2020, a Climate Risk function was set up, bringing together a network of correspondents in all the Group’s companies and business lines. It is led by the Climate Risks department of the Group Risk division. Climate risk correspondents are present in each entity and act as local relays. Their main task is to keep abreast of the latest developments in the industry, with a view to reporting them to their institutions’ management bodies and implementing them operationally. In 2021, the unit became the Climate Risk department reporting directly to Groupe BPCE’s Deputy Chief Executive Officer, a member of the Executive Management Committee in charge of Groupe BPCE risk. It defines and implements Groupe BPCE’s climate risk supervision system. The operational integration of this system in the institutions will make it possible to better integrate climate risks into the Group’s risk appetite.

The Climate Risk Committee, created in 2020, is chaired by the Chairman of the Management Board and brings together the heads of Groupe BPCE’s business lines, the Risk, Finance, Compliance and Impact functions and the Internal Audit, as well as two Groupe BPCE senior executives. This decision-making and monitoring committee deals with climate issues from a cross-functional perspective for the Group and its various business lines. It is in charge of examining the Group’s main existing or potentially emerging climate and environmental risk areas. It develops scenarios and validates the climate stress test transition matrices to assess the resilience and vulnerability of the Group’s business model. The Climate Risk Committee validated the update of the remediation plan to the ECB’s guide on climate and environmental risks, following the ECB’s thematic review carried out during the first half of 2022 and tracks its progress. At the end of 2023, close monitoring of remediation work, directly involving Groupe BPCE’s Executive Management Committee and the Supervisory Board’s Risk Committee, was set up to secure the production of the main deliverables expected in 2024.

EXCLUSION POLICIES IN SENSITIVE SECTORS

To take account of environmental, social and governance (ESG) issues, CSR policies for internal or public use have been introduced and integrated into the risk policies of business lines working in the most sensitive sectors.

THERMAL COAL

As early as October 2015, Natixis CIB committed to no longer financing any coal-fired power plant or thermal coal mine projects worldwide.

This commitment is being progressively strengthened and are thus excluded:

In 2021, Groupe BPCE extended its policy to all its banking activities and, in addition to the above-mentioned objectives, committed to a total phase-out of thermal coal by 2030 for OECD countries and 2040 for the rest of the world.

At the end of December 2023, Groupe BPCE’s exposure to coal industry financing represented less than 0.1% of the Group’s total exposure to corporate loans, i.e. a residual amount of less than €0.35 billion.

https://groupebpce.com/en/csr/actor-in-the-environmental-transition

OIL AND NATURAL GAS

As part of its policy applicable to the oil and gas industry, Groupe BPCE excludes:

DEFENSE INDUSTRY

Natixis CIB excludes the financing, investment and provision of services to companies involved in the production, storage and trade of anti-personnel mines and cluster munitions. This policy sets precise criteria for the conditions under which operations are carried out, particularly those relating to the countries of export and import.

https://natixis.groupebpce.com/wp-content/uploads/2022/08/200909_final_amended_cl_defense_policy_eng__v7.pdf

TOBACCO INDUSTRY

Natixis CIB has undertaken to cease all dedicated financing related to tobacco activities, as well as all non-dedicated financing in favor of a company whose business is 25% or more tobacco-based. Further to this commitment, Natixis has published a detailed tobacco sector policy which applies to Natixis’ financing and services activities.

https://natixis.groupebpce.com/wp-content/uploads/2022/08/180518_-_cl_tobacco_policy_-final-vf.pdf

OTHER INDUSTRIES

Natixis CIB has CSR policies for internal use for the nuclear, mining & metals and palm oil sectors. These policies, which apply to fundraising activities, cover the following aspects:

Natixis Investment Managers’ European management companies also apply sector and/or exclusion policies (see details in the dedicated paragraph below).

For BPCE Assurances’ activities, policies have also been defined in the coal, oil and gas, tobacco and controversial weapons sectors (see details in the dedicated paragraph below).

INCORPORATION OF ESG CRITERIA INTO FINANCING ACTIVITIES

Various tools have been developed to provide for the incorporation of ESG criteria into financing activities. These tools are adapted to the challenges identified for the different types of customers carried by retail banking and Corporate & Investment Banking.

RETAIL BANKING

Within the scope of retail banking, in addition to the coal policy applied to all Groupe BPCE companies, environmental criteria have been systematically integrated into sector policies since 2018.

In addition, the Non-Financial Risk Committee (CoREFI), comprising the Climate Risk, Credit Analysis and Impact teams, has been meeting regularly since March 2020 to carry out ESG reviews of all business sectors and by customer typology. As part of these reviews, each business sector is assessed on the basis of the six environmental challenges defined by the European taxonomy: physical climate risks, transitional climate risks, biodiversity, water, pollution other than greenhouse gases and the circular economy. An environmental sectoral classification follows from this assessment and identifies specific points of attention. Elements of a social and societal nature, and finally on sustainable governance, also enrich these sectoral analyzes.

The latter are intended to feed into discussions, particularly when granting credit, by providing additional analytical elements in the light of regulatory and market developments.

At the same time, the integration of ESG issues within the bank has continued with the deployment of a strategic ESG dialogue initiated with corporate customers. This dialogue is based on a questionnaire used by account managers to gather information on their customers’ knowledge, actions and commitment to climate and environmental issues. This ESG dialogue has been deployed in Groupe BPCE networks since the beginning of 2023.

NATIXIS CIB

The management of environmental, social and governance (ESG) risks in the financing and investment business lines is part of a global approach involving the business lines, CSR and control functions. This approach includes in particular the development and implementation of CSR policies in the most sensitive sectors, the definition of the excluded business sectors, the evaluation and monitoring of the ESG risks of transactions and counterparties via various tools and processes.

For the most sensitive sectors, CSR policies have been introduced and integrated into the risk policies of the business lines working in the sectors concerned. These policies are described in the previous section “Exclusion policies in sensitive sectors”.

When a new customer enters into a relationship, a process for identifying environmental and societal risks is put in place as part of the Know Your Customer (KYC) approach, which identifies and assesses environmental, social and governance (ESG) risks. Each customer company evaluated is assigned a level of vigilance based on four themes (controversies to which the client may be exposed, sectors in which the customer operates, maturity of the management system risks and type of business relationship with Natixis).

As part of the Equator Principles, Natixis CIB also applies a market methodology that aims to assess the environmental and social risks of projects financed and the management of these risks by customers, regardless of their business sector. Since October 2020, Natixis CIB has applied the amended version of the Principles (EP Amendment IV), which includes more exhaustive criteria regarding respect for human rights (including the rights of indigenous communities) and requires the analysis of physical and transition climate risks.

The Sustainability team produces detailed analyzes of Natixis CIB customers for whom ESG risk is considered a major concern. The number of transactions subject to this type of analysis over the last three years is 1,429 (including 614 in 2023).

The operational management of Natixis CIB’s climate trajectory is based on two complementary and interdependent systems: the Green Weighting Factor (GWF), an internal management tool used to guide operational financing decisions, and the monitoring of public sector decarbonization trajectories at Groupe BPCE level within the framework of the NZBA.

Within Natixis CIB, the Green Weighting Factor integrates criteria linked to exposure to the risk of biodiversity loss and its pressure factors for financing customers in sectors where the impact on biodiversity is material. These criteria are also included in the environmental rating of dedicated financing (project or asset financing) by taking into account their location in Key Biodiversity Areas.

Internal control system

Natixis CIB has an internal control system that incorporates all risks, including environmental and social risks. It is based on three lines of defense:

INCORPORATION OF ESG CRITERIA INTO ASSET MANAGEMENT ACTIVITIES

AT NATIXIS IM

For NIM, incorporating ESG factors into the investment process leads to more informed decisions, a better understanding of corporate risks, the identification of sustainable investment trends and the selection of companies that contribute to these trends. This approach aims to create long-term value for customers.

Several affiliates have developed dedicated non-financial research capabilities and integrated sustainability criteria into their investment decision support models. They rely on proprietary systems and raw data to establish their own scoring models and methodologies, which they can then transparently explain to customers.

By way of illustration, DNCA Finance relies on a proprietary ABA (Above and Beyond Analysis) assessment tool, which is built around five pillars: analysis of corporate responsibility risk, contribution to sustainable transition, monitoring of controversies, monitoring of engagement activities and finally impact on the UN’s sustainable development Goals (SDGs). This analysis does not include external agency assessments.

For fund-of-funds management, NIM Solutions complements its quantitative sustainability analysis with a proprietary qualitative “Conviction & Narrative” approach that includes, but is not limited to, the following criteria: the ESG experience of the investment team, the incorporation of ESG factors into the underlying funds’ investment processes, the transparency of ESG reporting and voting practices. The objective of the analysis model thus put in place is to:

Responsible investment policies

Each NIM management company is responsible for its own investment process, and ultimately for integrating environmental, social and governance factors in line with their fiduciary duty.

European asset management companies have developed responsible investment policies that explain their overall ESG approach, provide detailed guidance on the integration of environmental factors, and explain their sector and/or exclusion policies. All European asset management companies ban controversial weapons from their investments, and have exclusion policies in the coal, non-conventional oil and gas, and tobacco sectors. Some affiliated asset management companies have developed more restrictive exclusion policies, based on recognized frameworks for fossil fuels. The majority of asset management companies offering investment products in non-listed assets completely exclude fossil fuels in favor of transition and renewable energies.

For example, Ostrum Asset Management, which accounts for more than a third of Natixis IM’s assets under management, has been committed to sustainable development and responsible financing for over 35 years⁽¹⁾. Over time, it has developed its approach, which today combines three pillars: the incorporation of material ESG factors into the analysis of all asset classes, the exclusion of sectors or issuers that are not acceptable in portfolios, and the financing of transition for sectors or issuers that are ready to follow the path of transition and commit to themes that encourage just transition.

In addition, AEW Europe, which manages real estate assets, has implemented a specific exclusion policy tailored to its business sector.

The majority of non-European affiliates have developed a global responsible investment approach that formalizes their commitment to incorporating material environmental, societal and governance factors into their investment processes. They implement specific restrictions at the request of customers.

Engagement policy with portfolio companies

Beyond exclusion, Natixis Investment Managers sees engagement and dialogue with companies and issuers as significant levers for positively influencing corporate governance. Natixis IM’s European asset management companies have developed engagement and voting policies that encourage companies to transform their strategy and reduce their ESG risks, while contributing to environmental and social issues.

Engagement and dialogue have also enabled affiliates to develop in-depth knowledge of the companies in which they invest and their ESG challenges. As shareholders, the funds managed by Natixis IM affiliates are committed to contributing to the improved performance of companies by taking into account their stakeholders and the environment.

Affiliates such as Mirova, Ostrum AM, DNCA Finance and Ossiam explicitly include climate risk in their voting policies. Dorval AM and AEW Europe actively monitor the greenhouse gas emissions of companies and assets in their portfolios.

Environmental themes such as biodiversity (Mirova, Ostrum AM, Thematics AM, DNCA Finance), energy consumption (AEW), waste management (Thematics AM, DNCA Finance) and water management (DNCA Finance, Thematics AM) are also taken into account by affiliates.

At the social level, several affiliates, including Mirova, Ossiam, AEW Europe, MV Credit, Seventure Partners, Flexstone Partners and Vauban IP, strive to promote diversity.

Internal control system and organization

Natixis Investment Managers has an internal control system that integrates all risks, including environmental and social risks. It is built around three lines of defense and is organized operationally on two levels: a holding company in charge of supervising and coordinating the system, and affiliates responsible for risks and for implementing policies and controls:

AT PALATINE ASSET MANAGEMENT AND ECOFI

To exercise its voting rights, Palatine Asset Management (PAM) has been relying since 2015 on the expertise of ISS (Institutional shareholder Services Europe SA) to broaden its voting scope. The company ensures that its voting rights are exercised on the basis of the company’s specific context, in particular by taking into account its medium- and long-term strategic orientations, and its environmental and social policies. During the 2023 fiscal year, PAM exercised its voting rights at General Meetings concerning the companies making up the CAC 40 index, the companies making up the assets of SRI-labeled mutual funds, French companies whose consolidated holding threshold is greater than 0.50% of market capitalization, foreign companies held with a market capitalization in excess of €100 million and, since 2023, American companies held in the Palatine Amérique mutual fund. In other cases, a vote of support or dissent may be expressed from time to time. As a general rule, however, Palatine Asset Management does not exercise voting rights on any companies held below the set thresholds nor in countries with a POA (Power Of Attorney) where the voting procedure entails additional financial costs. The objective is to promote best ESG practices within those companies in which the funds managed by Palatine Asset Management are shareholders in order to encourage these latter to adopt an approach of progress and responsibility. The principles of this voting policy are available at https://www.palatine-am.com.

Within the subsidiary Ecofi, one of Groupe BPCE’s asset management companies, the voting policy and dialogue with stakeholders are at the heart of its corporate responsibility strategy. As planned in its engagement policy, Ecofi has undertaken in-depth and regular individual dialogue with several companies involved in controversies or with poor ESG performance. In a collaborative manner, Ecofi plays an active role in shareholder coalitions to which it is a signatory to influence the companies concerned on CSR issues. Lastly, as part of its voting policy, Ecofi votes at all General Meetings of companies invested by its funds under management through shares, without the requirement of holding a minimum threshold of capital (https://www.ecofi.fr/sites/default/files/Politique-Engagement_Ecofi.pdf).

In 2023, Ecofi exercised its voting rights at 279 General Meetings, representing a total of 4,534 resolutions submitted to shareholder votes. Ecofi voted “against” 42.5% of the resolutions, compared to the average “against” rate of French management companies, which stands at 20% (Source: AFG). The main purpose of votes against company resolutions concerns the appointment of members of the Board of Directors, followed by executive pay. Ecofi supported 111 resolutions of minority shareholders in favor of good governance and responsible management of environmental and social impacts.

In 2023, Ecofi dialogued individually with 35 companies: 13 dialogues focused on different ESG issues, 22 dialogues were conducted as part of a specific shareholder dialogue campaign on the subject of biodiversity. A total of 384 questions were formulated on several ESG themes, such as energy transition, biodiversity, human rights, social responsibility policies, governance and involvement in controversial episodes. Ecofi also supported 26 collective dialogue initiatives related to energy transition, biodiversity, human rights, employee relations and fiscal responsibility, through the international responsible finance networks of which Ecofi is a signatory. These 26 initiatives made it possible to contact 196 different invested companies. Finally, Ecofi took part in 12 dialogue initiatives with institutions relating to the following ESG issues: the quality of companies’ CSR reports, European regulations on Duty of Vigilance, Say on Climate, the filing of shareholder resolutions, plastic and water consumption, and greenwashing.

INCORPORATION OF ESG CRITERIA INTO INSURANCE ACTIVITIES

BPCE Assurances is committed to making a positive contribution to sustainable development objectives by implementing a selective ESG integration policy. Drawing in particular on Mirova’s analysis, BPCE Assurances aims to improve the ESG profile of its investments.

The aim of the policy is to achieve the following objectives: 15% of green assets in the annual flow until 2024 and 10% of green assets in the stock at the end of 2024 (“Green assets” being understood as green bonds, labeled funds [Greenfin], Article 9 funds validated following analysis by BPCE Assurances’ teams).

The policy is broken down by type of management:

INCORPORATION OF ESG INTO DIRECT MANAGEMENT

This is mainly carried out through mandates with Groupe BPCE entities (Ostrum, Mirova, Loomis).

Definition of the investment universe incorporating ESG criteria

BPCE Assurances applies a set of cumulative rules in defining the investment universe:

Green bonds review

A use-of-proceeds analysis is carried out by asset managers to validate the green bond designation (compliance with ICMA principles and verification of eligible assets).

ESG INCORPORATION IN INDIRECT MANAGEMENT, THROUGH THE SELECTION OF FUNDS FROM EXTERNAL MANAGEMENT COMPANIES:

CLIMATE RISK ANALYSIS APPLIED TO THE LIQUIDITY RESERVE

A non-financial analysis of the liquidity reserve has been carried out since December 2019.

In 2021, BPCE’s Financial Management department completed the indicators for monitoring the liquidity reserve with a breakdown of the securities portfolio by ESG rating of issuers (from A+ to D-) and a categorization of sustainable securities – green, social, sustainable and sustainable-linked. This information enables Groupe BPCE companies to better manage their portfolios and communicate on their incorporation of ESG criteria.

In order to have a Group vision and to manage the liquidity reserve in a dynamic way, the non-financial analysis was rolled out to all the Banques Populaires and Caisses d’Epargne in the summer of 2021 via a dynamic Power BI tool. This analysis is updated monthly.

Since December 2021, investments in counterparties with a non-financial rating of D+/D/D- are excluded following a decision by a Group Asset/Liability management Strategy Committee which applies to all Group institutions. A target of 17% of sustainable HQLA (High Quality Liquid Assets) securities by the end of 2024 has also been set.

In 2023, Groupe BPCE continued to implement the four strategic HR priorities included in the BPCE 2024 strategic plan:

In this context, the HR roadmap aims to:

Groupe BPCE is strengthening its role as a responsible employer by giving employees reasons to be proud of belonging to their company (notably through the Paris 2024 partnership) and, more broadly, to the Group. This ambition is designed to meet employees’ expectations in terms of professional fulfillment and development.

As a socially responsible employer, the Group respects:

Complete quantitative human resources indicators for Groupe BPCE are available at https://groupebpce.com/en/csr/a-socially-inclusive-employer

As in 2022, 2023 was marked by a dynamic and competitive job market. In this context, Groupe BPCE has, from 2022, intensified the work of the HR program of its Group strategic plan “Progressing in the network” on two aspects:

A “RECRUITMENT AND INTEGRATION” MARSHAL PLAN AT BANQUES POPULAIRES AND CAISSES D’EPARGNE

The HR function adapted quickly, with conclusive results in 2023.

In 2022 and 2023:

Conclusive results in 2023:

AN EFFICIENT RECRUITMENT SERVICE CENTER FOR NATIXIS AND BPCE SUBSIDIARIES

In 2023, the Mobility and Recruitment shared services center serving BPCE companies continued its work with teams dedicated by scope and expertise.

As in previous years, there is a shortage of profiles in control functions (particularly risk management) and IT functions.

The volume of new hires remains very high (11,358 employees), despite a slight fall at the end of the year. Natixis is continuing to roll out its new employer brand strategy to support its business lines’ development ambitions and take into account the expectations of applicants and employees. It is built around a value proposition: #transformative finance: “join us to make the difference,” consistent with its strategic ambition to support its customers in environmental, social and technological transitions.

GROUPE BPCE, AN INCLUSIVE EMPLOYER

MORE DIVERSIFIED PROFILES

Most of work-study student and young graduate recruits are in the commercial field, with a wide variety of profiles: from two to five years of higher education (BTS, Bachelor’s degree, Master’s degree), as well as engineers, particularly for the IT subsidiaries.

The Group’s companies, which are also open to profiles undergoing retraining, offer hiring and training opportunities to non-banking sector profiles, as long as they have proven interpersonal and commercial skills.

Special attention is also paid to profiles still in high demand, IT and Data.

PROMOTING THE PROFESSIONAL INTEGRATION OF YOUNG PEOPLE AND USING WORK-STUDY PROGRAMS AS A LEVER FOR PRE-EMPLOYMENT.

The Group has hired over 4,200 young people under the age of 30 on permanent contracts.

In addition, the Group makes the professional integration of young working people a priority area of its recruitment policy.

Within the framework of the new Management of Jobs and Career Paths (GEPP) agreement of July 2022, this policy is expressed by 2024 through quantified ambitions:

For the first time in 2023, Groupe BPCE tested a work-study conquest plan comprising:

A NUMBER OF WORK-STUDY STUDENTS WELCOMED INTO THE COMMERCIAL NETWORK IN BP AND CE WHICH INCREASES EACH YEAR: ONE IN THREE WORK-STUDY STUDENTS IS HIRED AT THE END OF THEIR COURSE

All these initiatives have led to a significant increase in the number of work-study students in the Banques Populaires and Caisses d’Epargne sales network.

The Group has also made the development of its “BPCE Campus” ATC a training facility for young people and pre-employment training for the Banques Populaires and the Caisses d’Epargne. When it was created in 2020, it had 47 work-study students compared to 300 in 2023, spread across some twenty companies.

In 2023, Natixis and the other BPCE business lines pooled their participation in numerous forums in order to be present to a greater number of schools and students. This provided an opportunity to showcase the diversity and richness of the Group’s jobs and expertises.

Lastly, working to promote equal opportunities and employment for young people, Groupe BPCE has implemented various initiatives:

INTEGRATING AND RETAINING NEW EMPLOYEES

Groupe BPCE places the onboarding and retention of new employees at the heart of its HR policy by striving to better “pre-welcome” and welcome newcomers, considering that the onboarding process and the employee experience begin as soon as the candidate signs his or her employment contract until he or she spends three years with the company.

In this context, the GEPP agreement expressly states that each Group company is committed to implementing a genuine onboarding program from the signing of the contract until the employee completes three years of service:

All the Banques Populaires and Caisses d’Epargne have revamped their onboarding programs for new recruits (on average, 40 days are devoted to learning the job).

INTRODUCTION

GROUP CODE OF CONDUCT AND ETHICS

Groupe BPCE’s Code of Conduct and Ethics Standards was validated by the Executive Management Committee and the Supervisory Board in 2018, after review by the Cooperative and CSR Committee, and was updated in October 2023.

The principles of ethical and professional conduct set out in this code are considered fundamental by BPCE’s Supervisory Board, Management Board and Executive Management Committee, as well as by all Group executives.

The Code is based on principles of conduct divided into three parts – customer interests, employer responsibility and corporate social responsibility – with a business line-specific approach for practical cases.

With the Code of Conduct and Ethics Standards, Groupe BPCE is committed to building lasting relationships of trust with our customers, partners and suppliers, and to acting with integrity in the exercise of our business line activities, while complying with the highest behavioral standards of transparency and confidentiality.

To read it in detail, here is the link where it is referenced, Code of Conduct and Ethics Standards of Groupe BPCE:

https://groupebpce.com/content/download/34841/file/Code conduite ethique-FR.pdf

GUIDING PRINCIPLES

Groupe BPCE’s Code of Conduct, which is reflected in the codes of conduct and charters of the Group’s entities, is a guarantee of a high-quality working environment and long-term reputation.

The rules of conduct are illustrated by real-life situations in which any employee, manager or director may find him or herself. The scenarios enacted serve as benchmarks to help them discern the right decision to make in the exercise of their profession.

While the Code of Conduct and existing internal policies and procedures provide clear guidance on how to behave, it is not possible to define a rule for every situation. Employees must exercise their judgment to make the right decision, drawing on the principles set out in the Code of Conduct.

The following questions are used to make an ethical decision in case of doubt:

MANDATORY KNOWLEDGE OF THE CODE OF CONDUCT BY ALL EMPLOYEES

Regulatory training, in e-learning format, has been developed to ensure that the principles of the Code of Conduct and Ethics Standards have been learned. This training is mandatory for all Group employees and for all new hires. As of December 31, 2023, 97.4% of registered employees had completed the training.

Another training course entitled “The Essentials of Ethics” completes the package. It consists of 15 sketches illustrating concrete cases of behavior to be avoided.

Since the end of 2019, a “Conduct and Ethics” dashboard, covering the Group’s scope, lists 35 indicators collected from the Group’s entities. It is presented twice a year to the Cooperative and CSR Committee of the Supervisory Board (ninth edition presented in November 2023). It collects data and information on the deployment of the system, incidents, disciplinary sanctions and types of breaches.

WHISTLEBLOWING SYSTEM

Groupe BPCE has a whistleblowing system applicable to all Group entities. A procedure, updated in 2023, can be downloaded from the Group website:

https://groupebpce.com/en/the-Group/compliance

Against a backdrop of much more protective legislation for whistleblowers (see the act of March 21, 2022), the Group has chosen to equip itself with the same tool for all Group institutions, regardless of the country in which they are based (Europe, the United States, etc.) and regardless of the business line (retail banking, Corporate & Investment Banking, etc.).

All Groupe BPCE employees and service providers have direct access to this tool via a URL link. The screens to which the whistleblower has access have been translated into more than 15 languages in line with the countries in which Groupe BPCE operates.

It offers all guarantees in terms of data security, complies with the highest standards in terms of confidentiality and respect for anonymity (encrypted data, inability to retrieve the IP addresses of whistleblowers, etc.). The whistleblower may send his or her alert and discuss it with the person managing it, with or without anonymity. The alert is sent directly to the department responsible for handling it thanks to the definition of routing rules specific to each institution – these rules contribute to confidentiality.

In addition, a training system based on e-learning accompanies the deployment of the tool and specifies the rights and duties of a whistleblower as well as the protection attached to it. It has been rolled out to Group employees since July 2023.

OTHER ELEMENTS OF THE ETHICS SYSTEM

The Group also has a framework procedure relating to Ethics which describes the entire system applicable to all Group institutions. It brings together all the normative documents relating to this system and specifies the roles and responsibilities of each player. This document mainly comprises the rules that apply to all the Group’s institutions, and also includes best practices.

In addition, the Group has developed procedures and tools for declaring gifts and benefits to employees, and for managing and preventing conflicts of interest that may arise in the course of their duties.

PREVENTION OF CORRUPTION

Groupe BPCE condemns corruption in all its forms and under all circumstances, including facilitation payments. It is a signatory of the United Nations Global Compact, whose tenth principle is “Businesses should work against corruption in all its forms, including extortion and bribery.”

CORRUPTION PREVENTION MECHANISMS

The Group’s employees are required to comply with the internal rules and procedures that help to prevent and detect behaviors likely to characterize acts of corruption or influence peddling. The following rules and mechanisms make it possible to comply with the requirements introduced by Article 17 of act No. 2016-1691 of December 9, 2016 on transparency, the fight against corruption and the modernization of the economy (“Sapin 2”):

Groupe BPCE also has accounting standards and procedures that comply with professional standards. The Group’s internal control system for accounting information is based on a structured audit process to check the conditions in which such information is assessed, recorded, stored and made available, in particular by verifying the existence of the audit trail. A Group control framework has been drawn up to help prevent and detect fraud, corruption and influence peddling, and its deployment at all sites is monitored by Group Financial Control.

Generally speaking, these systems are formalized and detailed in the charter governing the organization of Group internal control and the Risk, Compliance and Permanent Control Charter.

FIGHT AGAINST MONEY LAUNDERING AND THE FINANCING OF TERRORISM, COMPLIANCE WITH INTERNATIONAL SANCTIONS (EMBARGOES AND ASSET FREEZES)

The effective implementation of these two financial security systems within Groupe BPCE is based on:

COMBATING MONEY LAUNDERING AND THE FINANCING OF TERRORISM

The system to combat money laundering and the financing of terrorism (AML/CTF) is based on the following pillars:

COMPLIANCE WITH SANCTIONS (EMBARGOES AND ASSET FREEZES)

With respect to compliance with national, European or foreign sanctions, Group institutions are equipped with screening tools that generate alerts on customers (asset freezes on certain individuals or entities) and filtering on international flows (asset freezes and countries subject to European and/or US embargoes).

Groupe BPCE also has a central alert processing team and is constantly improving its customer screening and transaction filtering tools. In order to strengthen the effectiveness of their processing, a dedicated face-to-face training module has been set up.

STRENGTHENING OF THE SYSTEM IN 2023

ML-TF risk mapping has evolved significantly, in 2023, with the updating of a section entirely dedicated to the fight against terrorist financing, which identifies and assesses the risks of radicalization and/or terrorist financing, whatever the ideological underpinning, and presents prevention and mitigation measures.

In terms of KYC and ML-TF risk profile assessment, the Politically Exposed Persons (PEP) detection tool has been optimized several times since 2021 to gain in efficiency and reliability. With regard to updating customer knowledge based on ML-TF risks, various actions targeting certain customer categories have been carried out over the past two years, following on from the remediation action carried out since 2021 on high-risk customer files.

In terms of detecting transactions linked to the financing of terrorism, the monitoring system has been strengthened by the weekly delivery of alerts to financial security institutions.

In anticipation of the 2024 deadlines, a number of projects have been initiated, such as redesigning the interface used to draw up reports to TRACFIN, preparing the computer queries needed to extract the data that will feed the new annual reporting to the ACPR (QLB), and redesigning the format of periodic reports to improve the depth of analysis.

In terms of permanent control, a wide-ranging review of the Group’s AML-CTF and Sanctions procedures was carried out within the Group’s institutions and certain subsidiaries during 2023.

Operational expertise certifications in terms of AML-CTF financial security were issued in 2023, as part of the expertise program rolled out in 2021. The gradual increase in the number of award-winners testifies to the level of knowledge and skills of the function’s employees. New registrations were opened for the 2024 fiscal year.

EMPLOYEES TRAINED IN ANTI-MONEY LAUNDERING POLICIES AND PROCEDURES

FIGHTING AGAINST INTERNAL FRAUD

Groupe BPCE has set up a common system to combat internal fraud, non-compliance with internal rules and breaches of ethics, in line with the Group’s Code of Conduct and Ethics Standards. This system makes it possible to meet the requirements of the supervisory authorities and to pool the resources and work carried out by the establishments. It is formalized in a framework procedure and consists of the following elements:

THE POLICY ON COMBATING TAX EVASION AND GROUP TAX POLICY

Although it mainly operates in France through its retail banking networks, Groupe BPCE also operates abroad through its subsidiary Natixis.

In this respect, the Group’s establishment abroad is justified by the need for commercial support for its clients, which excludes any consideration of offshore operations due to the existence of preferential tax regimes in certain jurisdictions.

Groupe BPCE supports its customers by ensuring that its advice complies with applicable tax regulations. The Group does not provide tax advice to its customers.

Groupe BPCE’s tax policy is determined by BPCE SA. However, Group companies are responsible for its implementation in their respective activities.

Groupe BPCE ensures its full compliance with all tax regulations applicable to its activities. As such, Groupe BPCE ensures that it makes its fair contribution to public finances.

In France, income taxes for the 2023 fiscal year came to €1,340 million, comprising €1,264 million in current taxes and €76 million in deferred taxes, giving an effective tax rate of 32.04%.

Other taxes and regulatory contributions totaled €886 million, including the contribution to the Single Resolution Fund of €457 million.

In 2023, Groupe BPCE continued to solicit the tax authorities to secure the tax treatment of corporate tax and VAT transactions as part of the fiscal partnership with the French Ministry of Public Action and Accounts active since 2019. This regular and transparent dialogue with the administration covered various areas of tax law. Groupe BPCE was the first bank to be admitted to this new system.

GROUPE BPCE HAS VERY MARGINAL OPERATIONS IN NON-COOPERATIVE COUNTRIES AND TERRITORIES (“ETNC”)

France has, by the Ministerial Order of February 16, 2024 published in the Official Journal on February 17, 2024, updated its list of non-cooperative countries and territories (hereafter “ETNC”).

The new list includes the following 16 jurisdictions (including three new ones - Belize, Russia, Antigua and Barbuda):

It should be noted that the French list of ETNCs is now identical to the EU list with the exception of the Seychelles, Bahamas, Turks and Caicos Islands and Belize, which remain on the French list but not on the EU list.

The Group is not included in the list of ETNCs, with the very marginal exception of the Fiji Islands, Vanuatu and Russia. These locations meet the needs of customers for commercial support.

This situation of a marginal presence in these non-cooperative countries and territories was noted by a study by Eurotax Observatory published on September 21, 2021 on the establishments in low-taxed states of 36 European banking groups over the period 2014-2020.

This study notes that only 2.2% of Groupe BPCE’s profits are made in countries or territories with low taxation rates, compared to an average of 20% for the other European banks in the study.

The same study noted that Groupe BPCE’s effective tax rate is 30%, placing it among the highest among European banks. Indeed, the average effective tax rate of the European banking groups was 20% and the lowest observed was 10%.

FINANCING OF PUBLIC LIFE

Groupe BPCE does not directly support any specific political party, whether in the form of donations, sponsorship or any other means. The Group is strictly neutral in political matters. On the other hand, as a leading banking player in France, Groupe BPCE establishments contribute to the financing of public life, in accordance with the strict legislative and regulatory framework existing in France in this area, and in compliance with the rules on KYC, Anti-Money Laundering (AML), and Politically Exposed Persons (PEP). Its involvement is therefore at two levels:

Lastly, Groupe BPCE is in constant contact with the mediation of loans and financing to candidates and political parties set up by Article 28 of act No. 2017-1339 of September 15, 2017, for Trust in Political Life.

PURPOSE OF THE DUTY OF CARE

Act No. 2017-399 of March 27, 2017 on the Duty of Care of parent companies and ordering companies (the “act”) requires the establishment and effective implementation of a Duty of Care plan. The plan includes reasonable vigilance measures to identify risks and prevent serious violations of human rights and fundamental freedoms, health and safety of people and the environment, resulting from the company’s activities and those of the companies it controls, as specified below, as well as the activities of suppliers or subcontractors with which there is an established commercial relationship, when these activities are related to this relationship.

The act also requires the preparation of an annual report on the effective implementation of the Group’s Duty of Care plan. This plan must include risk mapping, measures to assess and mitigate the risks of serious harm, monitoring their implementation and an alert mechanism.

The main components of the Duty of Care plan and the report on its effective implementation are included in this section.

SCOPE

As a parent company, BPCE SA draws up a Duty of Care plan and reports on the effective implementation of this plan for BPCE SA and the companies it directly or indirectly controls within the meaning of Article L. 233-16 II of the French Commercial Code. This entity will be referred below under the name “BPCE.”

The list of subsidiaries under exclusive control is given in paragraph 13.4 of the consolidated financial statements of BPCE SA Group, Section 5.3 of the universal registration document under point III-3 – BPCE subsidiaries (FC statutory consolidation method).

Where necessary, it should be noted that the Banques Populaires and the Caisses d’Epargne are not subsidiaries of BPCE SA, and therefore do not fall within the scope of the Duty of Care plan set out below.

GOVERNANCE OF THE DUTY OF CARE

The Duty of Care plan was prepared by the Impact department, the CSR departments of the business lines (retail banking, Insurance, Global Financial Services), the Risk division, the Human Resources department, the Group Security department, BPCE Achats, the Compliance department and the Legal department. The effective implementation of the Duty of Care plan is the responsibility of the business lines/subsidiaries and functional departments concerned.

In terms of ESG issues and risks, a cross-functional approach has been adopted, involving specialized committees chaired by the Chairman of the Management Board or one of the members of the Executive Management Committee. Themes related to the Duty of Care are regularly addressed: environmental transition, responsible employer, Conduct and Ethics reporting.

The 2023 Duty of Care plan was presented to the Executive Management Committee.

The Duty of Care plan approach is based on the principle of continuous improvement. It is subject to change in line with the results of regularly assessed risk mapping, changes in the activities carried out, financed or induced by the internal operations of the entities covered, and priority issues identified in terms of ESG.

PRINCIPLES AND APPROACH

The vigilance measures implemented by Groupe BPCE are based on its purpose: “resolutely cooperative, innovative and committed players, retail bankers and insurers, Groupe BPCE companies and employees support their cooperative shareholders and customers with financial solutions adapted to each one and build a sustainable and responsible relationship with them” and on the three ESG axes of the BPCE 2024 strategic plan: Meeting the expectations of civil society, Becoming a major player in the environmental transition and Shaping the future of work.

The Group complies with the entire regulatory framework to which it is subject as a company and as a bank, both locally and internationally. These regulations include the fight against money laundering, the financing of terrorism and the circumvention of international sanctions, the prevention of internal fraud and the prevention of corruption.

Groupe BPCE is a signatory of the United Nations Global Compact and join the “Ten Principles,” which two relate to Human Rights:

Groupe BPCE is also committed to applying the guiding principles on business and human rights set out in the United Nations’ “Protect, Respect and Remedy” framework.

As a responsible bank and company, the Group places professional ethics at the heart of its operating model. Compliance with the rules of good conduct by employees enables each entity to carry out its activities honestly, loyally and professionally, and to serve the best interests of its customers. The Group’s convictions and commitments have been set out in the form of “Principles” in Groupe BPCE’s Code of Conduct and Ethics Standards. “Promoting respect for human rights in all our activities” is one of the Group’s core values.

When drawing up the plan, the Group’s activities are analyzed from the point of view of their impact and the risks of serious harm they could cause in terms of human rights and fundamental freedoms, personal health and safety, and the environment.

The following challenges have been identified:

The scope of the vigilance approach is based on three pillars:

EMPLOYEE PILLAR

As part of the implementation of its BPCE 2024 strategic plan, Groupe BPCE is strengthening its role as a committed and socially responsible employer, by deploying an active HR policy that responds both to employees’ expectations and to the challenges of a fairer society, taking into account the transformation of its business lines.

The Group is committed to respecting and promoting human rights, which is one of the cornerstones of its corporate social responsibility.

BPCE has a solid social foundation, made up of a set of voluntary charters, agreements and operational measures, ensuring the protection of employees, as well as the safety of individuals in the exercise of their profession.

At December 31, 2023, 32,615 employees were working for BPCE, 28% of them outside France. Natixis, part of BPCE, groups together the Group’s global business lines and employs 14,179 people (15,039 including Financial investments), 49.5% of whom work outside France.

IDENTIFICATION AND PRIORITIZATION OF CSR RISKS: RISK MAPPING

In employee relations, areas of vigilance include: working conditions; health and safety at work; diversity, inclusion and prevention of discrimination; freedom of association and collective bargaining.

These issues are already strictly governed by a number of existing regulations, notably in France, by Labor Law and by policies on the safety of people and property.

Groupe BPCE is present in 50 countries with very contrasting levels of risk in terms of human rights, health and safety. A review was carried out at Natixis sites, where the majority of employees work internationally. A map has been drawn up to identify more specifically the risks relating to working conditions, discrimination and personal safety in the various Natixis sites. These assessments are based on recognized external databases, such as ILO (International Labour Organization) statistics or the ITUC (International Trade Union Confederation) Global Rate Index.

In addition, the Security department is responsible for assessing risks (security, safety, health, natural disasters) in the countries where Group companies are based, using a Travel Risk Management tool.

On the basis of these analyses, the sites with more than 50 employees (Natixis scope) that present a risk in terms of human rights, health and safety are as follows: Algeria, China, Hong Kong, India and the United Arab Emirates. These five sites accounted for 1,498 employees at the end of 2023, representing 10% of Natixis’s worldwide headcount (including Financial investments) and 4.6% of BPCE’s headcount.

SYSTEM FOR MONITORING VIGILANCE MEASURES AND REPORTING ON THE IMPLEMENTATION OF RISK PREVENTION OR MITIGATION MEASURES

All our companies assess occupational hazards and target appropriate preventive actions and solutions. Each has a Social and Economic Committee and a Health, Safety and Working Conditions Commission (CSSCT).

Working conditions

Employment management is carried out within the framework of collective agreements, which cover the following main themes: management of jobs and career paths (GEPP); mandatory annual negotiations; quality of life and working conditions; health, welfare and retirement; safety of people and property at Groupe BPCE level.

Remuneration policies are based on the sharing and creation of value through its health and personal protection, profit-sharing and incentive schemes. These schemes are negotiated at company level.

Remuneration policies comply with current laws and regulations, including minimum social benefits. The principles relating to the composition of remuneration and its evolution are in line with the objectives of each Group entity. They are based on the principles of fairness and gender neutrality, and include an annual review for all employees.

All forms of forced labor are prohibited by the Group. Group entities are also required to check the age of all new employees on hiring.

At Natixis worldwide, HR departments are implementing measures to guarantee benchmark standards for HR policies. At the five sites considered to be at risk, employee working conditions are checked to ensure that they comply with or improve local regulations:

Health and quality of life at work

Within Groupe BPCE, quality of life at work and working conditions (QLWC) are about creating an environment that enables everyone to do a good job, so as to reconcile customer satisfaction, social progress and economic performance. Concrete actions are implemented to improve the quality of work, to facilitate the reconciliation of private and professional life, and to maintain the physical, mental and social well-being of our employees. Each Group company has appointed a QLWC contact.

To better support sensitive situations (chronic illnesses, family caregivers, single parenthood etc.), companies are implementing increasingly comprehensive measures covering a broad spectrum, from information to financial support, including training, assistance with procedures, psychological support, a more suitable organization of work, maintaining ties during long-term absences and preparation for a return to work. 26 Groupe BPCE companies, including BPCE SA, Natixis and Banque Palatine, have signed the Cancer@Work Charter.

Psychosocial risks related to work/life balance are monitored as part of the occupational risk management program. Since 2017, BPCE has been a signatory of the Charter of Fifteen Commitments to Lifetime Balance, and in 2020 it signed a collective agreement with representative trade unions on new ways of organizing work and their consequences on working conditions.

BPCE assesses the satisfaction and well-being of its employees by means of feedback systems which, by giving employees a voice, make it possible to identify the consequences of the ongoing transformations on the work Group. This overview of impacts makes it possible to guide the support plan and, if necessary, to adjust the transformation.

Employee commitment is measured every two years through the Groupe BPCE Diapason social engagement barometer: drawn up with IPSOS. Other surveys and barometers are carried out on an ad hoc or regular basis, such as YourPulse, to measure employee satisfaction and well-being. The results, shared with employees, help to better define their expectations and give rise to action plans. Complementary reporting systems enable employees to report problems in their work/life balance at any time.

In 2023, the main achievements within BPCE were as follows:

Safety at work

Supervision of the safety of people and property is carried out by the Group Security department within the Group’s Corporate Secretary’s Office. Each year, it draws up an inventory and assessment of risks (including fire, assault, traffic, biological, chemical, heatwave and extreme cold). Property safety covers security risks (theft and damage) and major risks (fire, industrial and natural hazards).

It draws up and implements annual plans for the prevention and improvement of working conditions, and monitors claims by means of indicators at company level and for the Group as a whole⁽¹⁾. Incident management is based on the implementation of resources for monitoring, detecting and dealing with emergencies.

Indeed, it is on the basis of a fourfold observation – a high number of workplace accident claims, heterogeneous company practices, the absence of a common risk management tool and the continuous tightening of regulations – that a global approach to occupational risk prevention, common to the Group’s institutions, has been implemented since 2021.

Its action plan is currently being rolled out. It relies in particular on a management tool with full functional coverage. Multi-disciplinary teams can interact and share elements contributing to the improvement of occupational risk prevention: such as: Single Document – Action Plans – Safety Visits – Workstation Instructions – Training – Workplace Accidents/Occupational Illnesses – Incivilities – Periodic Checks – Statistics.

Groupe BPCE companies are subject to French regulations. International subsidiaries with local regulations specifying the controls to be carried out are also concerned by the deployment of Groupe BPCE’s Permanent Controls for the Safety of People and Property.

Within the Groupe BPCE scope, there were 923 workplace accidents with lost time in 2023 (vs. 860 in 2022).

Diversity, inclusion and prevention of discrimination

For several years now, the Group has been committed to promoting diversity and gender equality, as illustrated by the signature of various charters and the implementation of specific measures:

In 2023, the main achievements for Groupe BPCE were as follows:

Within Groupe BPCE, in 2023, the proportion of female managers was 46% and the proportion of female senior managers 35%. The equal pay index is 92/100 (stable vs 2022).

Indicators such as the employment rate of disabled people (6.12% for Groupe BPCE in 2022 vs. 6% in 2021).

Freedom of association and collective bargaining

At Group level, dialogue with employee representatives takes place through three bodies: the Group Works Council, a forum for information and exchange, and the Strategy Committee, a forum for sharing and dialogue on the strategic plan and vision, as well as the body for negotiating Groupe BPCE agreements.

It is also supported by annual follow-up commissions concerning the GEPP and the career paths of mandated employees.

In 2023, the Group Committee and the Strategy Committee each met twice, while the GEPP Monitoring Committee and the Committee for Monitoring the Career Paths of Mandated Employees met once.

PURCHASING PILLAR – SUPPLIERS AND SUBCONTRACTORS

IDENTIFICATION AND PRIORITIZATION OF CSR RISKS: MAPPING

As part of an AFNOR-supported initiative, BPCE Achats and three other banking groups have drawn up a CSR risk map based on a common nomenclature comprising over a hundred purchasing categories (142 in 2022).

The level of risk for each purchasing category is assessed along three axes covering the following issues:

Presented to the Purchasing and CSR departments from 2018 and associated with the Duty of Care plan, this mapping makes it possible to identify, rank and prioritize, by purchasing category, the CSR risks to be monitored with suppliers. It also incorporates the risk associated with the country in which the majority of the added value on each product and service is generated. An update of this mapping was carried out in 2022.

Each purchasing category is assessed on a scale of four CSR risk levels: low, limited, high, very high. To assess the level of risk, the AFNOR expert takes into account the probability and potential severity of the risk for each factor.

Purchasing categories identified as carrying a high or very high CSR risk include work on buildings, waste recycling, IT equipment, vehicles, promotional items, ATMs, energy, air travel, furniture, etc.

SYSTEM FOR MONITORING VIGILANCE MEASURES AND REPORTING ON THE IMPLEMENTATION OF RISK PREVENTION OR MITIGATION MEASURES

BPCE Achats deploys a responsible purchasing policy, involving the Group’s companies and their suppliers. This policy is based on the following principles of action: integration of CSR criteria at every stage of the purchasing process, evaluation of suppliers’ CSR performance, measurement of the environmental impact of purchasing projects, promotion of the economic and social development of the local economic fabric, development of the use of inclusive suppliers.

The action plans implemented by BPCE Achats as part of its responsible purchasing policy involve suppliers in the implementation of vigilance measures. The Banking Sector’s Responsible Purchasing Charter, a reference document for tender documents, formalizes the reciprocal commitments of the Group and its suppliers.

The assessment of CSR risks by BPCE Achats is based in particular on:

Based on the risk assessment work, specific mitigation measures were developed:

As part of its efforts to promote a sustainable and balanced relationship with suppliers, BPCE Achats has set up regular meetings with the Group’s strategic suppliers (defined in particular according to the volume of purchases, the criticality of the services delivered for the continuity of banking activities and/or essential to the Group’s development). The aim of these meetings is to understand the supplier’s strategy (innovation, HR, external growth, etc.), its market positioning and trends, in order to adjust the Group’s strategy accordingly. They are part of a process of managing the Group’s challenges and risks with a key supplier, and they also make it possible to better challenge partners on common issues, such as CSR.

BPCE Achats has set up a system to assess supplier risks, as part of the controls led by the AFA (French Anti-Corruption Agency), the implementation of obligations to prevent and detect corruption in companies, and, where applicable, sanctions, in line with the obligations of the Sapin 2 law.

Several criteria are taken into account: sanctions, the presence of Politically Exposed Persons (PEPs), negative press (fraud, corruption, etc.), country of establishment and business sector. Suppliers are classified according to their level of risk (rating). In the event of high risk, an additional questionnaire is sent to the supplier, whose answers are analyzed by a dedicated team.

The implementation of this system was shared with the Crédit Agricole Group’s Purchasing department, with the choice of Altares’ IndueD platform.

ACTIVITIES PILLAR - CUSTOMER RELATIONS AND FINANCING AND INVESTMENT ACTIVITIES

IDENTIFICATION AND PRIORITIZATION OF CSR RISKS: RISK MAPPING

The areas in which the Group’s activities could give rise to risks to human rights and fundamental freedoms, the health and safety of individuals and the environment are:

All business sectors are regularly reviewed from an ESG perspective. Each sector is assessed on the basis of the six environmental issues defined by the European taxonomy: mitigation – transition climate risk, adaptation – physical climate risk, biodiversity, pollution (other than greenhouse gases), water and the circular economy. The assessment is based on a dual materiality analysis: impact on the activity of companies in the sector (financial materiality) and impact of the activity of companies in the sector on the environment and social aspects (impact materiality). An environmental sectoral classification follows from this assessment and identifies specific points of attention. Elements of a social and societal nature and sustainable governance enrich these sectoral analyses.

For the Environment axis, the sectors in which the Group’s corporate customers are most exposed are: international trade in commodities, metals, oil and gas, agri-food, construction and public works, basic industry.

For the Social axis, the most exposed sectors are oil & gas, basic industries, healthcare – pharmaceuticals, IT and technology.

SYSTEM FOR MONITORING VIGILANCE MEASURES AND REPORTING ON THE IMPLEMENTATION OF RISK PREVENTION OR MITIGATION MEASURES

FOR THE FINANCING AND INVESTMENT COMPONENT

For several years now, BPCE has been committed to incorporating ESG criteria into its financing and investment activities.

At the heart of BPCE’s concerns, the environmental transition is one of the three pillars of the BPCE 2024 strategic plan. The Group’s objectives are to commit its balance sheet over the long term to a strategy of mitigating the climate impact of its activities and of the assets it finances or insures, by aligning its financing portfolios on a “Net Zero” trajectory, i.e. carbon neutrality by 2050, to support its customers in their own energy transition challenges, and to accelerate the reduction of its direct environmental footprint.

Exclusion policies in sensitive sectors

In order to limit the human and environmental impacts of its financing, investment and insurance activities, Groupe BPCE has withdrawn from activities with the highest emissions and for several years has been developing sectoral policies, including exclusion criteria, to regulate its activities in the most sensitive sectors.

For banking activities, these policies cover the following sectors: coal, oil and natural gas, the defense industry and the tobacco industry (for Natixis CIB). In the nuclear, mining and metals and palm oil sectors, Natixis CIB also applies specific non-public policies.

For example, in 2023, Groupe BPCE strengthened its criteria in the oil and gas sector by excluding:

For BPCE Assurances’ activities, policies have also been defined in the coal, oil and gas, tobacco and controversial weapons sectors.

For asset management activities, European management companies apply sector and/or exclusion policies.

Portfolio decarbonization trajectories

Groupe BPCE is committed to aligning its financing and insurance portfolios, with the aim of achieving carbon neutrality by 2050.

To amplify its actions and strengthen the framework for steering the climate alignment of portfolios, the Group joined the Net Zero Banking Alliance initiative for its banking activities in July 2021 and the Net Zero Asset Owner Alliance for its insurance activities in October 2022.

As part of its membership of the Net Zero Banking Alliance and in line with its commitments to align the trajectory of its portfolios with the goal of carbon neutrality in 2050, Groupe BPCE published intermediate alignment targets in December 2022 for two of the most emissive sectors:

These targets have since been raised:

In December 2023, Groupe BPCE broadened its ambition to reduce carbon emissions by publishing new targets to 2030 for three sectors within the scope of Corporate & Investment Banking (Natixis CIB): automotive, steel and cement.

Management of environmental and social impacts in financing activities

In retail banking, ESG criteria have been systematically integrated into sectoral policies since 2018 at the rate of sectoral policy updates.

The ESG sector scores for each business sector, regularly updated by the CoREFI (Non-Financial Risk Committee), are intended to provide additional information for discussion, particularly when granting loans, in the light of regulatory and market developments.

In retail banking activities, the integration of ESG issues continues with the deployment since the beginning of 2023 of a strategic ESG dialogue with corporate customers. This dialogue is based on a questionnaire used by account managers to gather information on their customers’ knowledge, actions and commitment to climate and environmental issues.

At Natixis CIB, ESG risk management is part of a global approach involving the business lines, CSR and control functions. This approach includes developing and implementing CSR policies in the most sensitive sectors, defining excluded sectors of activity (see exclusion policies above), and assessing and monitoring the ESG risks of operations and counterparties.

When a new customer enters into a relationship, a process for identifying environmental and societal risks is put in place as part of the Know Your Customer (KYC) approach, which identifies and assesses environmental, social and governance (ESG) risks. Each customer company evaluated is assigned a level of vigilance based on four themes (controversies to which the customer may be exposed, sectors in which the customer operates, maturity of the risk management system and type of business relationship with Natixis).

As a signatory of the Equator Principles, Natixis CIB applies a market methodology recognized by the member banks and institutions aiming to assess the environmental and social risks of the projects financed and the management of its risks by customers regardless of their sector of activity. CSR policies in sensitive sectors include criteria to respect human rights and ensure working conditions. The Mining and Metals policy, for example, excludes forced child labor and small-scale mining. Since October 2020, Natixis CIB has applied the amended version of the Principles (EP IV Amendment) which includes more comprehensive criteria in terms of respect for human rights (including the rights of indigenous communities) and which requires the analysis of physical and transitional climate risks

Natixis also integrates an in-depth analysis of the impact on biodiversity into its project financing operations: in application of the Equator Principles, Natixis requires its customers to study all the potential risks and impacts of their projects from an environmental, social, health and safety perspective, and to implement all necessary means to minimize and correct potential impacts. Damage to biodiversity is an integral part of this vigilance. The quality of the impact studies and management systems put in place by the customer is taken into account in the project assessment. Generally carried out by an independent consultant, the assessment pays particular attention to the preservation of natural habitats and critical habitats, in line with the regulatory framework applying to the project. For projects located in non-designated countries, additional actions are required to meet International Finance Corporation conditions.

Mining for the extraction of raw materials, their valorization and transformation has a significant impact on natural capital and biodiversity. That’s why Natixis works with its customers to plan, avoid, reduce and offset the impact of these projects at every stage of the investment process. The Energy Transition & Natural Resources (ETNR) team ensures that its customers follow industry best practices (including the Equator Principles) and Natixis internal policies for every transaction.

The Sustainability team produces detailed analyses of Natixis CIB customers for whom ESG risk is considered a major concern. The number of transactions subject to this type of analysis over the last three years is 1,429 (including 614 in 2023).

The operational management of Natixis CIB’s climate trajectory is based on two complementary and interdependent systems: the Green Weighting Factor (GWF), an internal management tool used to guide operational financing decisions, and the monitoring of public sector decarbonization trajectories at Groupe BPCE level within the framework of the NZBA.

Within Natixis CIB, the Green Weighting Factor integrates criteria linked to exposure to the risk of biodiversity loss and its pressure factors for financing customers in sectors where the impact on biodiversity is material. These criteria are also included in the environmental rating of dedicated financing (project or asset financing) by taking into account their location in Key Biodiversity Areas.

Management of environmental and social impacts in investment activities

Natixis Investment Managers (Natixis IM), along with 18 of its affiliated asset management companies⁽¹⁾ worldwide, representing a total of over 1,000 billion in assets under management, are signatories to the UNPRI (United Nations Principles for Responsible Investment). As such, they are committed to respecting the six PRI principles, including the incorporation of environmental, social and governance (ESG) factors into investment analysis and decision-making processes, and to actively engaging with companies by including sustainability issues in their engagement policies and practices. The UNPRI provides a recognized framework for integrating ESG factors into investment processes, with annual reporting obligations to which affiliates have complied.

For Natixis IM’s affiliated asset management companies, incorporating ESG factors into the investment process leads to more informed decisions, a better understanding of corporate risks, the identification of sustainable investment trends and the selection of companies that contribute to these trends. This approach aims to create long-term value for customers.

Several affiliates have developed dedicated non-financial research capabilities and have integrated sustainability criteria into their investment decision-making models. They rely on proprietary systems and raw data to establish their own scoring models and methodologies that they can then transparently explain to customers.

By way of illustration, DNCA Finance relies on a proprietary ABA (Above and Beyond Analysis) assessment tool, which is built around five pillars: analysis of corporate responsibility risk, contribution to sustainable transition, monitoring of controversies, monitoring of engagement activities and finally impact on the UN’s sustainable development Goals (SDGs). This analysis does not include external agency assessments.

For fund-of-funds management, NIM Solutions complements its quantitative sustainability analysis with a proprietary qualitative “Conviction & Narrative” approach that includes, but is not limited to, the following criteria: the ESG experience of the investment team, the incorporation of ESG factors into the underlying funds’ investment processes, the transparency of ESG reporting and voting practices. The objective of the analysis model thus put in place is to:

RESPONSIBLE INVESTMENT POLICIES

Each Natixis Investment Managers management company is responsible for its own investment process, and ultimately for integrating environmental, social and governance factors in line with their fiduciary duty.

European asset management companies have developed responsible investment policies that explain their overall ESG approach, provide detailed guidance on the integration of environmental factors, and explain their sectoral and/or exclusion policies. All European asset management companies ban controversial weapons from their investments, and have exclusion policies in the coal, non-conventional oil and gas, and tobacco sectors. Some affiliates have developed more restrictive exclusion policies, based on recognized reference frameworks for fossil fuels. The majority of asset management companies offering investment products in non-listed assets completely exclude fossil fuels in favor of transition and renewable energies.

For example, Ostrum Asset Management, which accounts for more than a third of Natixis IM’s assets under management, has been committed to sustainable development and responsible financing for over 35 years⁽¹⁾. Over time, it has developed its approach, which today combines three pillars: the incorporation of material ESG factors into the analysis of all asset classes, the exclusion of sectors or issuers that are not acceptable in portfolios, and the financing of transition for sectors or issuers that are ready to follow the path of transition and commit to themes that encourage just transition.

In addition, AEW Europe, which manages real estate assets, has implemented a specific exclusion policy tailored to its business sector.

The majority of non-European affiliates have developed a global responsible investment approach that formalizes their commitment to incorporating material environmental, societal and governance factors into their investment processes. They implement specific restrictions at the request of customers.

At December 31, 2023, assets under management in Articles 8 and 9⁽²⁾ accounted for 40.5% of total assets managed by NIM affiliates (vs. 36.7% at the end of 2022).

ENGAGEMENT POLICY WITH PORTFOLIO COMPANIES

Beyond exclusion, Natixis Investment Managers sees engagement and dialogue with companies and issuers as significant levers for positively influencing corporate governance. Natixis IM’s European asset management companies have developed engagement and voting policies that encourage companies to transform their strategy and reduce their ESG risks, while contributing to environmental and social issues.

Engagement and dialogue have also enabled affiliates to develop in-depth knowledge of the companies in which they invest and their ESG challenges. As shareholders, the funds managed by Natixis IM affiliates are committed to contributing to improved corporate performance by taking into account their stakeholders and the environment.

Affiliates such as Mirova, Ostrum AM, DNCA Finance and Ossiam explicitly include climate risk in their voting policies. Dorval AM and AEW Europe actively monitor the greenhouse gas emissions of companies and assets in their portfolios.

Environmental themes such as biodiversity (Mirova, Ostrum AM, Thematics AM, DNCA Finance), energy consumption (AEW), waste management (Thematics AM, DNCA Finance) and water management (DNCA Finance, Thematics AM) are also taken into account by affiliates.

At the social level, several affiliates, including Mirova, Ossiam, AEW Europe, MV Credit, Seventure Partners, Flexstone Partners and Vauban IP, strive to promote diversity.

FOR THE INDIVIDUAL CUSTOMER RELATIONSHIP COMPONENT

The Group is subject to a number of regulations (anti-money laundering, anti-corruption, personal data protection, compliance with embargoes, etc.), which form the regulatory basis of its risk management. Internal policies to prevent risks to customers, such as customer privacy, data protection and cybersecurity, complete the package.

Customer protection – Supervision of commercial practices

In the context of the distribution of financial products and services to individual customers, the protection system includes a set of rules relating to the validation of marketed products, commercial processes (whatever the sales channel used: direct sales, online sales, telephone sales, etc.) and advertising.

Employees are responsible for passing on offers to customers in a transparent and correct manner, as part of a relationship of trust. Customer protection must be effective at each stage of the relationship. Several years ago, the Group introduced a system of professional certification, enabling it to verify that the presentation, advice and sales of financial products and services to customers are carried out by employees with the appropriate professional knowledge.

A clear, transparent procedure for handling customer complaints enables each institution to track and analyze malfunctions by type. The feedback system is used both as a complaints management tool and as a means of continuously improving the range of banking products and services. Each institution also has an independent mediator, whose contact details are clearly indicated on customer documents and on customer websites.

Complaints management focuses in particular on the grounds for complaint, the products and services concerned by these complaints and the processing times. Key indicators are regularly submitted to Groupe BPCE bank directors, Internal Control departments and all sales structures.

Among the reasons for complaints, indicators are monitored which may reveal discrepancies between the service expected by the customer and the service provided, such as information and advice for 1.6% of complaints handled in 2023 and unauthorized transactions for 1.5%, down compared to 2022.

Personal data protection and prevention of cybersecurity risks

The prevention of risks related to cyber threats, the preservation of information systems, the protection of data, and particularly the personal data of customers and employees are major objectives at the heart of the Group’s concerns.

In terms of personal data protection, the Group is committed to ensuring that the processing of personal data it implements complies with the GDPR and the French Data Protection Act, and pays particular attention to the responsible use of data. The Group data protection policy sets out the standard organization, the roles of the various stakeholders and the application of the GDPR regulation within the Group. Incident handling is centralized within a tool, which also enables the formalization of Level 2 GDPR controls and the monitoring of associated action plans. Employees are regularly trained and made aware of compliance with the GDPR and the Privacy by Design approach.

The purpose of the information sheet is to provide our customers with detailed information on how BPCE protects them when processing personal data relating to security, compliance, audit, marketing, communication, finance and risk.

The Cybersecurity strategy is based on a reference framework, policies and a repository of permanent controls defined at Group level and deployed operationally at the level of each entity.

In 2023, deployment of the Group’s cybersecurity strategy continued, with in particular: a Group program dedicated to identity and rights management, the launch of a program to comply with regulations on operational resilience (reinforcement of access security to the Group’s IS, single authentication portal for Group employees, widespread use of strong authentication), continued execution of the awareness-raising plan, and the review of the Group’s IT network security model.

In the area of personal data protection, Groupe BPCE’s customer exercises of rights fell by 23% in 2023 due to an exceptional level. There has been a sharp decrease in the right to be forgotten (22%) in favor of rectification rights and access rights. With a quarter of requests, opposition rights remained stable. As last year, portability rights are almost non-existent (38 requests recorded). In 2023, 51 data breaches resulted in a notification to the CNIL, i.e. a level almost identical to 2022.

Non-discrimination – Accessibility of the offer and inclusive finance

The Group is committed to helping vulnerable customers by promoting banking inclusion and implementing measures to prevent overindebtedness, offering them specific support and protective measures to help them return to a stable financial situation. Specific training modules on vulnerable customers and the right to an account are compulsory for retail advisors in branches and on telephone platforms. To promote financial inclusion, the Group also supports microcredit, i.e. specific loans for people in need of economic and social integration, who are excluded from conventional credit due to low income or unforeseen circumstances.

FOR ACTIVITIES CONTRIBUTING TO BPCE’S DIRECT ENVIRONMENTAL FOOTPRINT

The environmental risks associated with BPCE’s operations (direct impact of facilities) are not such as to create serious environmental nuisances. In addition, the Group is already subject to strict environmental regulations, notably in Europe and the United States, and is implementing numerous initiatives to limit its impact on the environment (e.g. label-certified buildings, reduced consumption of resources, waste management, optimized travel etc.).

As part of its BPCE 2024 strategic plan, Groupe BPCE has set itself the target of reducing carbon emissions related to its own activity by 15% over the period 2019-2024. At the end of 2023, the reduction in the Group’s carbon footprint since 2019 was 15%.

WHISTLEBLOWING MECHANISM

Act No. 2017-399 on the Duty of Care of parent companies and ordering companies requires the implementation of a whistleblowing and reporting mechanism.

The whistleblowing system set up by Groupe BPCE as part of the fight against fraud and corruption has been extended to allow the reporting of facts falling within the scope of the Duty of Care. This system is applicable in all Group entities and is described in a procedure, updated in 2023. This specific system can be consulted on the Group’s website (https://groupebpce.com/en/the-groupe/compliance) and reports can be made on the secure Whispli platform (https://bpce.whispli.com/speakup?locale=en).

The whistleblowing system is open to all employees and third parties, who can express their concerns via a URL link if they are aware of serious violations of human rights and fundamental freedoms, personal health and safety, or the environment.

Groupe BPCE has chosen to equip itself with the same tool for all of the Group’s institutions, regardless of the country in which they are based (Europe, United States, etc.) and regardless of the business line (retail banking, Corporate & Investment Banking, etc.). Consequently, all the screens to which the whistleblower has access have been translated into more than 15 languages, in line with the countries in which Groupe BPCE is based.

Groupe BPCE entities protect whistleblowers. Under no circumstances may they be subject to any disciplinary action or legal proceeding, provided they have acted impartially and in good faith. The system implemented by Groupe BPCE offers every guarantee in terms of data security, complies with the highest standards in terms of confidentiality and respect for anonymity (encrypted data, impossibility of recovering whistleblowers’ IP addresses etc.), as required by the act of December 9, 2016 known as the “Sapin 2” law as amended by act No. 2022-401 of March 21, 2022 aimed at improving the protection of whistleblowers.

In addition, an e-learning training program has been launched for all employees and new arrivals to support the roll-out of the tool and provide information on the rights and duties of a whistleblower, as well as the protection afforded to whistleblowers.

Regulatory framework

To encourage sustainable investment, EU Regulation 2020/852 of June 18, 2020 (Taxonomy Regulation) established a common EU classification system to identify economic activities considered environmentally sustainable.

The Taxonomy Regulation (Article 8) requires companies subject to the Non-Financial Reporting Directive (NFRD) (which in France is reflected in the Non-Financial Performance Statement) to provide information on the manner and extent to which their activities are associated with economic activities that can be considered environmentally sustainable. As of fiscal years opening after January 1, 2024, this system will be integrated into the sustainability report in application of the CSRD (Corporate Sustainability Reporting Directive) published on December 16, 2022.

An activity is considered “eligible” for the Taxonomy if it is included in the European Commission’s evolving list. These are activities likely to make a substantial contribution to at least one of the following six environmental objectives:

To be effectively considered environmentally sustainable, an eligible activity must be “aligned” with the Taxonomy, i.e. it must meet the following three cumulative conditions:

The technical criteria for documenting the environmental sustainability of an activity are set out in delegated acts. To date, two delegated regulations have been issued for this purpose:

This was amended for the first time on March 9, 2022, by delegated regulation 2022/1214, which included, under strict conditions, specific activities linked to nuclear energy and gas on the list of economic activities covered by the Union’s taxonomy. It applies from January 1, 2023.

A second amendment was published on June 27, 2023 (delegated regulation 2023/2485) completing the technical examination criteria for certain activities that were initially not listed as eligible (in particular, manufacture of essential equipment for low-carbon transport or electrical equipment). It comes into force from January 1, 2024;

The content of sustainability indicators (Key Performance Indicators or KPIs) and the information to be published by non-financial and financial companies (asset managers, credit institutions, investment firms and insurance and reinsurance companies) subject to these transparency obligations, are specified, for each of these economic actors, in the delegated regulation article 8 of July 6, 2021 (2021/2178). The format of publishable tables is governed by Environment Delegated Regulation 2023/2486.

Additional information is required for companies that carries out, fund or has exposures to specific activities related to nuclear energy and fossil gas (Delegated Regulation 2022/1214).

In addition, European Commission communications published in the official journal on October 20, 2023 aim to interpret certain provisions relating to the implementation of Article 8 of the Taxonomy Regulation (C/2023/305) and the delegated act relating to the climate component of the taxonomy (C/2023/267).

On December 21, 2023, the Commission published a draft communication on the interpretation and implementation of Article 8 Taxonomy, which clarifies the information to be provided. Given its late publication and the implementation work involved, this text is currently being analyzed, and some of its provisions will be applied in the coming period.

The Taxonomy Regulation provides for a gradual implementation of information transparency requirements according to economic players. Groupe BPCE, as a company in the financial sector, is notably subject to publication requirements that are staggered by one year compared with non-financial companies. This principle allows financial companies to use eligibility and alignment data communicated by counterparties themselves subject to these publication requirements (NFRD counterparties) in order to weight their investments, financing and other exposures.

Groupe BPCE publishes disclosures applicable to financial companies – credit institutions.

MAIN INDICATOR – GAR (GREEN ASSET RATIO)

For the first two years (2021 and 2022), the main indicator to be published – the Green Asset Ratio (GAR), indicated the proportion of activities “eligible” for the first two environmental objectives, according to the criteria of the taxonomy regulations.

The GAR at December 31, 2023 includes taxonomy alignment data for the first time. It is presented in the tabular format required by regulations. This requires presentation once on the basis of the “Turnover” KPI and once on the basis of the “CapEx” KPI (capital expenditure) of counterparties subject to NFRD.

Information on eligibility for the four non-climate objectives (sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems) is based on data published by non-financial companies, which publish this information for the first time in 2024. As a result, at December 31, 2023, Groupe BPCE does not provide this information and the columns in the regulatory tables relating to this information are not presented. Similarly, the tables presenting information relating to the comparative period, which are not required at December 31, 2023 for financial companies, are not presented. Also, GAR Flow, the calculation methods for which were set out in the FAQ published by the Commission on December 21, 2023, is not presented as at December 31, 2023.

Groupe BPCE will publish all this information as of December 31, 2024.

The regulations also provide for the publication of indicators based on the trading portfolio and fees and commissions by 2026 (based on 2025).

BREAKDOWN OF GAR OUTSTANDINGS BY BUSINESS SECTOR (NACE CODE)

This table shows, by sector (NACE code), the gross carrying amount of banking exposures to non-financial counterparties subject to NFRD, and their proportion aligned with the taxonomy criteria.

KPI FOR OFF-BALANCE SHEET EXPOSURES (FINANCIAL GUARANTEES GIVEN AND ASSETS UNDER MANAGEMENT)

These two indicators are published for the first time on December 31, 2023. Like the GAR, they indicate the proportion of eligible and aligned oustandings with the taxonomy.

INFORMATION ON NUCLEAR ENERGY AND FOSSIL GAS ACTIVITIES

Five detailed tables must be provided, once on the basis of the main KPI – GAR (Turnover basis), once on the basis of the main KPI – GAR (CapEx basis).

As of January 1, 2024, in view of the clarifications provided by the European Commission, these tables will also be presented for KPIs relating to GAR flow and off-balance sheet exposures (financial guarantees given and assets under management).

Mandatory GAR

GUIDELINES

The main indicator applicable to credit institutions is the Green Asset Ratio (GAR). Expressed as a percentage, it indicates the proportion of assets that finance or are invested in economic activities aligned with the taxonomy in relation to the total assets covered.

SCOPE OF FINANCIAL ASSETS SUBJECT TO ELIGIBILITY AND ALIGNMENT ANALYSIS

On the basis of the prudential perimeter established in accordance with FINREP regulations (investments in insurance companies controlled by Groupe BPCE are consolidated using the equity method), assets are presented at their gross carrying amount, i.e. before depreciation, provisions and amortization.

The eligibility and alignment analysis applies to a scope of assets determined following a series of exclusions specified by the regulations:

The above exposures subject to eligibility and alignment analysis thus include balance sheet assets in the following accounting categories:

METHODOLOGY USED

In accordance with the principles of the regulations and our ability to implement them, the eligibility and alignment of the outstanding amounts of assets subject to eligibility and alignment analysis are determined:

Eligibility and alignment were only measured using data available in Bloomberg. These data are not always exhaustive, in particular for data relating to the eligibility of financial companies. The Group’s eligibility ratio is penalized by this lack of data;

For documentation of the substantial contribution to climate change mitigation criterion relating to real estate financing:

The analysis of alignment with the taxonomy’s criteria must then be supplemented by technical criteria demonstrating that the activity does not cause significant harm to the taxonomy’s other objectives (DNSH criterion):

The alignment analysis for renovation loans was not carried out in the absence of data available to document compliance with the taxonomy criteria.

In the absence of available data (CO₂ emissions/km), alignment of motor vehicle loans has not been performed;

Insurance activities are included in Group indicators through the equity-accounted investments in subsidiaries, presented on the “equity instruments” line. The eligibility and alignment of insurance activities is determined by applying to non-life insurance entities the underwriting ratio (share of gross written premiums received corresponding to insurance or reinsurance activities aligned with the taxonomy) and to life or combined insurance activities the investment ratio (share of investments devoted to financing economic activities aligned with the taxonomy). Due to operational constraints, eligibility and alignment have not been taken into account as of December 31, 2023.

SUMMARY OF GAR

At 12/31/2023

DETAIL OF GAR – TURNOVER BASIS

At 12/31/2023

DETAIL OF GAR – CAPEX BASIS

At 12/31/2023

The information relating to GAR is presented below in accordance with the model tables applicable to credit institutions as set out in Annex VI of Delegated Regulation 2023/2486.

Off-balance sheet indicators: financial guarantees given and assets under management

GUIDELINES

From December 31, 2023, in accordance with Section 1.2.2. of Annex V of the Delegated Regulation 2021/2178, credit institutions shall publish additional indicators on exposures not recognized as assets on the balance sheet relating to:

METHODOLOGY USED

The method used to calculate KPI for financial guarantees and KPI for assets under management consists in applying to exposures the eligibility and alignment rates of counterparties subject to NFRD.

SUMMARY OF OFF-BALANCE SHEET KPIS

DETAIL OF GAR ON OFF-BALANCE SHEET EXPOSURES - TURNOVER

At 12/31/2023

DETAIL OF GAR ON OFF-BALANCE SHEET EXPOSURES - CAPEX

At 12/31/2023

Information on KPIs for financial guarantees and KPIs for assets under management is presented below in accordance with the model tables applicable to credit institutions as set out in Annex VI of Delegated Regulation 2023/2486.

Activities related to nuclear energy and fossil gas

GUIDELINES

Additional information is required for companies engaged in, financing or exposed to specific activities related to nuclear energy and fossil gas (Delegated Regulation 2022/1214). The tabular format is required by regulations. This requires the publication of these tables for each applicable KPI.

At December 31, 2023, Groupe BPCE presents this information for the main KPI – the GAR established in stock, once on the counterparties’ Turnover based KPI and once on counterparties’ CapEx based KPI.

At a later date, this information should also be presented for the main KPI – GAR in flow view, as well as for off-balance sheet KPIs: financial guarantees given and assets under management.

METHODOLOGY USED

The publication of model 1 is mandatory. This model is used to identify the specific activities in the gas and nuclear sectors covered by delegated act 2022/1214 of the Taxonomy Regulation.

Models 2 to 5 are presented by weighting the exposure to the counterparties concerned by the data communicated by them in their reference document for the previous year, collected from the Bloomberg database.

ALIGNMENT POLICY (REQUIREMENT OF ANNEX XI OF DELEGATED REGULATION 2021/2178) WITH THE TAXONOMY REGULATION

Groupe BPCE intends to commit to a long-term change in its balance sheet as part of a strategy to mitigate the climate impact of its activities and assets financed, invested or insured.

Groupe BPCE’s climate change strategy is described in this Chapter “Be a major player in the environmental transition”, particularly in terms of commitments with customers and counterparties.

The publication of so-called aligned activities will enhance its internal climate measures and green commitments. Groupe BPCE also takes into account the European taxonomy in the design of its “green” offers and services and aims to comply as much as possible with the alignment criteria. This requirement necessitates the collection of significant amounts of relative information, as well as detailed, documented analyses, for which further work will be carried out in the coming fiscal year.

TABLES TO BE PUBLISHED IN ACCORDANCE WITH ARTICLE 8 OF THE TAXONOMY REGULATION

Groupe BPCE publishes the tables required by the Taxonomy Regulation applicable to credit institutions in the tabular formats presented in Annex VI of Delegated Regulation 2023/2486.

TEMPLATE 0 - SUMMARY OF KPIS TO BE DISCLOSED BY CREDIT INSTITUTIONS UNDER ARTICLE 8 TAXONOMY REGULATION

TEMPLATE1 - ASSETS FOR THE CALCULATION OF GAR (TURNOVER BASIS)