AND ANNUAL FINANCIAL REPORT

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

Its 100,000 employees, serve 36 million customers around the world – individuals, professionals, businesses, investors, and local authorities. It provides retail banking and insurance services in France through its two major cooperative networks, Banque Populaire and Caisse d’Epargne. With Natixis, it also provides asset & wealth management, corporate & investment banking and payment services around the world.

www.groupebpce.com

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 only version that is binding in law.

The original Universal Registration Document was filed on March 23, 2022 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. Groupe BPCE’s 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, 50, avenue Pierre Mendès-France 75013 Paris.

Laurent MIGNON

Chairman of the Management Board

In 2021, we supported all our clients in reviving the economy, whether they are individuals, professionals, companies, local authorities or institutions, by fully playing our role in terms of financing retail banking, corporate & investment banking and as a major player in savings management.

All our business lines are growing and recorded remarkable performances in 2021: we owe these good results to the commercial dynamism of our brands - Banque Populaire, Caisse d’Epargne, Natixis, Banque Palatine, Oney - of course, but also to our decentralized cooperative model, our spirit of innovation and our ability to transform ourselves.

On this last point, 2021 continues to stand out for its major strategic projects.

First and foremost, the simplification of the organization of our Group with the delisting of Natixis, the creation of the Global Financial Services division, bringing together our two major global business lines of asset management and corporate & investment banking, the transfer of insurance and payment activities to BPCE, and the merger of the support functions of Natixis and BPCE.

It also brought together a common team dedicated to IT development in retail banking, with the creation of BPCE Solutions informatiques. Finally, in asset management, the simplification of our relations with the Banque Postale/CNP group, which enabled us to consolidate the structure of our asset manager, Natixis Investment Managers, and to extend our commercial partnerships.

All of these projects are part of our new BPCE 2024 strategic plan, which we presented last July. This development plan provides concrete answers - those of a responsible and committed group - to issues such as the environmental transition and healthcare. It sets ambitious targets for conquest by 2024, in all our businesses and in all our regions, with the aim of offering our customers a safe environment and the highest quality of service.

With our More United, More Useful and Stronger BPCE 2024 strategic plan, we aim to become a leader in banking, financial expertise, insurance and asset management by 2024, serving all our customers. This ambition will guide the actions of our companies, our business lines and all the functions at work in our Group starting this year.

“ In 2021, our Group sets out for 2024!

Groupe BPCE is the second-leading banking group⁽¹⁾ in France and finances over 20%⁽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 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, decentralized and unlisted, it allows our actions to take place over a long period of time with short decision-making circuits. This is how we combine the present and the future with efficiency and confidence.

Our new strategic plan, BPCE 2024, reaffirms this conviction: Groupe BPCE, with strong positions in each of its business lines, has the momentum to accelerate its development by supporting its customers with their investment needs for the economic recovery. It intends to deploy the full potential of its model to be a leader in banking, insurance and asset management at the service of all.

With its new BPCE 2024 strategic plan, the Group intends to take advantage of the economic recovery by leveraging new growth drivers. This three-year development plan is structured around three priorities and three key areas.

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

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

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

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.

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

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

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).

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 “D” 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

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

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

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.

COMMITMENT TO ALIGN GROUP PORTFOLIOS ON A “NET-ZERO” TRAJECTORY

Aligning the Group 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

Towards a low-carbon economy

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

Groupe BPCE was established in 2009 through the merger of Groupe Banque Populaire and Groupe Caisse d’Epargne. 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, the Group became the leading unlisted European banking group.

True to its roots, Groupe BPCE is as committed as ever to bringing about transformations and meeting the pressing challenges of its time, particularly when it comes to the energy and ecological transition.

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 nine million cooperative shareholders. This highly stable shareholding structure is imbued with a strong cooperative spirit.

BPCE SA, the central institution of Groupe BPCE, is wholly-owned by the 14 Banques Populaires and 15 Caisses d’Epargne. It defines the policies and strategic objectives of the Group and coordinates the sales 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.

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.

Important members 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.

January

Groupe BPCE has created an employer brand based on three key areas: vitality, freedom and commitment. The company’s true identity, it conveys its image, its characteristics and its uniqueness to its employees and potential candidates.

Mirova, the asset management company specializing in sustainable investment, affiliated with Natixis Investment Managers, participated in the creation of the Natural Capital Investment Alliance. This Alliance aims to mobilize $10 billion in favor of Natural Capital and make it a real investment opportunity through different asset classes.

February

The Group is launching a project to simplify its organization, which aims to provide each of its business lines with new room for maneuver to develop, transform and win new customers. The project includes a simplified takeover bid for Natixis shares by the Group, accompanied by an exit from listing.

On board Banque Populaire X, Clarisse Crémer crossed the finish line of the Vendée Globe in 12^th position and became the fastest solo woman to sail around the world in a monohull.

The Group finances very high-speed broadband in two départements, making it possible to connect more than 160,000 households in Côte d’Or and Landes. Natixis acted as the arranger, coordinator of Groupe BPCE’s response and as ESG coordinator. The Caisses d’Epargne Aquitaine Poitou-Charentes, de Bourgogne Franche-Comté and de Midi-Pyrénées co-arranged the financing of the transaction. Lastly, the Caisses d’Epargne de Normandie, Ile-de-France, BRED and Banque Palatine also acted as guaranteeing banks on a financing line.

March

Groupe BPCE furthered its commitment to gender diversity by signing a Charter, the aim of which is to share common convictions regarding gender diversity with all Groupe BPCE companies through ten concrete commitments to be pursued and developed over the years to come. With this signature, Groupe BPCE committed to promoting professional equality at the highest level of responsibility, systematically integrating the principle of gender equality in all HR processes, supporting female/mixed networks, and promoting and retaining talents.

Banque Populaire is supporting the transition of the agricultural model with the launch of the Agrilismat Green offer, to finance agricultural equipment. Banque Populaire has set itself a target of producing €1 billion in green loans by 2024, i.e. 20% of the total production in their territory of professional agricultural loans over the period.

April

The Group’s four banks – Banque Populaire Auvergne Rhône Alpes, Caisses d’Epargne Rhône Alpes, Loire Drôme Ardèche and d’Auvergne et du Limousin – are contributing to the creation of a public-private financing tool intended to strengthen the companies’ equity.

The Caisses d’Epargne created a debt fund with resources of €1.5 billion, in conjunction with Natixis and BPCE Énergéco. This fund is intended to finance major operations for the development of renewable energy projects of all kinds on a national scale: offshore and onshore wind, photovoltaic, energy storage, hydroelectricity, hydrogen and methanisation, etc.

May

BPCE L’Observatoire publishes Le temps des aidants. This new opus is dedicated to the 15 million French people who provide assistance to a loved one because of their health, disability or age.

June

Caisse d’Epargne launched its Pacte Utile (Useful Pact) which aims to make the Paris 2024 Olympic and Paralympic Games a lever for the transformation of society through inclusion through sporting activities, the financing of numerous sports infrastructures and support for athletes.

July

Launch of the “BPCE 2024 – More United, More Useful, Stronger” strategic plan. Its ambition: to be a leader in banking, insurance and asset management for everyone.

The simplified public tender offer initiated by BPCE resulted in the delisting of Natixis shares. With the success of this transaction, after 12 years of existence, Groupe BPCE became the largest unlisted cooperative banking group in Europe.

The Group joined the Net-Zero Banking Alliance, which aims to achieve carbon neutrality by 2050. Launched by the UN Environment Finance Initiative (UNEP FI), it brings together around 50 banking institutions mobilized against global warming.

Oney, a subsidiary of Groupe BPCE, confirmed its leadership by creating universal installment payments. With Oney+, consumers can pay in 3 times or 4 times anywhere in the world, on all channels, in all types of businesses and for all types of services.

August

The athletes and para-athletes supported by the Group’s companies shine at the Tokyo Olympic and Paralympic Games. They won more than 40% of the total medals won by the French delegation.

September

The quality of the funds designed, managed and distributed by the Group’s entities was recognized by the awarding of eight trophies at the 2021 edition of the Corbeilles Mieux Vivre votre Argent.

The Group became the main partner of Energy Observer, the first autonomous hydrogen vessel. It supports a project to develop technological solutions around hydrogen and contributes to the deployment of financing tools adapted to new technologies and green energy.

October

The Group and Natixis published their first Task Force on Climate-related Financial Disclosure (TCFD) report. In this document, they detail their actions to support the transition to a low-carbon economy and adaptation to the effects of climate change.

Natixis Corporate & Investment Banking signed cooperation agreements with LBBW in Germany and Tyndall Group in Chile with the aim of obtaining joint M&A advisory mandates and improving support for the international business development of their respective customers.

November

Banque Populaire was named the number one bank for SMEs for the 12^th consecutive year. This recognition reflects the historic commitment to serving SMEs but also the daily mobilization of the Banque Populaire banks, particularly during the past year.

An affiliate of Natixis Investment Managers, Ostrum AM is among the best-positioned players in the 2021 edition of the RIBI (Responsible Investment Brand Index), which assesses the ability of asset managers to translate their commitment to sustainable development into their identity and their brand.

December

La Banque Postale acquired BPCE’s 16.1% stake in CNP Assurances.

Stabilization of the terms and conditions between Groupe BPCE and La Banque Postale of the proposed acquisition by Natixis Investment Managers (a wholly-owned subsidiary of Natixis) of the minority stakes held by La Banque Postale in Ostrum Asset Management (45%) and AEW Europe (i.e. 40%). The planned acquisitions will enable Natixis Investment Managers to hold 100% of the capital of these management companies.

More than 3,000 companies and partners are committed to “Entreprendre 2024”, a system created in 2020 by Groupe BPCE to support its clients, small and medium-sized businesses, medium-sized companies, social economy organizations and social economy players and solidarity in the Paris 2024 adventure.

Banques Populaires

Founded by entrepreneurs for entrepreneurs more than 140 years ago, the Banques Populaires have stayed true to their roots, confirming their position as the leading bank for SMEs in France for the 12^th consecutive year.⁽¹⁾ A top-tier banking network with 12 regional Banques Populaires and two national affiliated banks (CASDEN Banque Populaire, dedicated to the civil service sector, and Crédit Coopératif, a bank serving the social and solidarity-based economy), Banque Populaire is also the No. 2 bank of craftsmen and small retailers.⁽²⁾

CASDEN BANQUE POPULAIRE

CASDEN furthered its development, achieving its goal of becoming the leading bank in the civil service sector. In 2021, 120,021 new cooperative shareholders, of which 71% are from the Civil Service excluding National Education, joined. Today, there are nearly 2.1 million cooperative shareholders.

As a cooperative and affinity bank, the satisfaction of the cooperative shareholders is preponderant: its NPS reached +10 in 2021, up by four points.

2021 was marked by the completion of several projects. The accessibility of new self-care services, such as the publication of an amortization schedule or obtaining an end-of-loan certificate, free of charge, in the cooperative shareholders’ personal space on casden.fr.

The enhancement of the loan offer, notably with Prevair and Autovair to finance more responsible and environmentally-friendly projects, and the “project loan”, which can be used according to individual needs.

CASDEN also announced the launch of its new strategic plan for 2022-2024, “Elan 2024”, based on a new development dynamic, a culture of performance and strong collective commitment.

Lastly, CASDEN supported three athletes who participated in the Tokyo Olympic and Paralympic Games all from the public service, notably Manon Brunet, who won two medals in saber: individual bronze and team silver.

The Caisses d’Epargne

The Caisses d’Epargne have financed the French economy for more than 200 years. They support their customers over the long-term and in all their life events, with the ambition to “Be Useful” to each and everyone. Individuals, professionals, non-profits, corporates and local authorities all receive personalized solutions from their Caisse d’Epargne, tailored to their individual needs and objectives. The 15 Caisses d’Epargne are cooperative banks, which make up the second largest banking network in France.

Banque Palatine

Since its creation, Banque Palatine has been a partner to intermediate-sized enterprises (ISEs) and private company directors. ISEs needing to finance a project, undertake capital transactions, or expand their business internationally can call on Banque Palatine to build tailored solutions and help with its customers’ projects based on extensive business and sector expertise. Private Banking experts draw on a comprehensive understanding of their customers’ personal and professional environment to construct a suitable long-term wealth strategy in consultation with them.

Activity

In the corporate market, the conquest mainly concerned companies with revenues of more than €15 million. The volume of new loans stabilized with activity focused on structured transactions on medium-sized companies. Corporate Finance had an excellent year: nearly €12 million in fees and commissions were generated, and €317 million in financing was co-arranged with Groupe BPCE entities.

In the private banking market, 2021 was marked by a very good level of activity with nearly 900 new core customers, SRI outstandings doubled to €102 million at December 31, 2021 and a strong increase in loan distribution at €577 million.

Green

After the crédit impact in 2020 (traditional loan with a contractual clause indexing the margin to the sustainable performance of the company based on social, environmental and governance criteria, for which the reduction in margin achieved was abandoned by Banque Palatine to a non-profit organization), Banque Palatine strengthened its green offering with the launch of the green calculator. This new tool gives real estate professionals who take out a loan, a “green” rating based on the objective criteria of their project. This rating is mentioned in the loan offer. Beyond a certain rating, the financial conditions are improved in favor of non-profits committed to sustainable development.

Professional equality

Banque Palatine published its index on gender equality in the workplace: at 97 points, it placed the bank among the best French companies, all sectors combined. In addition, it has had its Afnor label renewed for four years. Banque Palatine is also committed to the “digital Mixity” footprint, the first digital platform that reflects the overall diversity and inclusion impact of companies, schools, local authorities, non-profits, etc.

Oney

For 37 years, Oney has created payment, financing and insurance solutions adapted to the transformation of commerce, that enable millions of Europeans to improve their daily lives. As a retail partner, Oney plays a major role in supporting consumption by making it all possible: equipment needs, work and travel plans, health and education expenses, and the management of unforeseen expenses. Oney deploys an inclusive vision of its business lines. And because it wants to guarantee sustainable performance and act positively for society, Oney is committed to ensuring that everyone has the power to consume better.

In 2021, Oney recorded a good level of activity, with production up 16% year-on-year.

It confirmed its leadership in split payment activities in France but also in Portugal, Italy and Romania. A new offer was launched this year with Oney+ which includes a payment account, a Visa bank card and an “app”. Consumers can pay in 3 or 4 times anywhere in the world, on all channels, in all types of businesses and for all types of services.

Major new partnerships were signed with e-merchants: at the end of 2021, more than 1,700 e-merchants trusted it, from very small businesses to international groups, in all retail sectors.

Two years after BPCE took a stake in Oney, cooperation with Groupe BPCE companies is under way. This is notably the case with the payment service provider PayPlug in the preparation of common responses to certain calls for tenders, with S-money in the construction of the innovative solution Oney+ which makes split payment universal, and with BPCE Financement, the Caisses d’Epargne and the Banques Populaires to offer their professional customers the Oney split payment solution.

Finally, in 2021 Oney launched a European Circular Consumption Observatory to support its customers and partners in their ecological and economic transition.

The Insurance Business Unit

The Insurance Business Unit designs and manages a comprehensive range of personal insurance products (life insurance, retirement savings vehicles, payment protection insurance, and individual provident insurance) and non-life insurance products (automotive, multi-risk home, supplementary health insurance, personal accident insurance, legal protection, non-banking insurance, etc.). After the successful deployment of the #INNOVE2020 project, it is now the sole insurance platform serving the Banque Populaire and Caisse d’Epargne networks, which consolidates Groupe BPCE’s position as a leading bancassurer in France. The strategy implemented since 2014 is now paying off: the sales momentum recorded in 2021 was very intense and sustained. Groupe BPCE Insurance Business Unit is now one of the Top 10 insurers and the Top 5 bancassurers in France.

The year 2021 was marked by the launch of many new or renewed offers. Responding to the new demands, new needs and modes of consumption of customers, they were all redesigned with a view to offering a simpler and more fluid experience with the highest standards of service quality. This was the case for the new motorcycle insurance, borrower insurance and life insurance offerings. In addition, the marketing of the Natixis Life offering, already available through the Banque Populaire network, was extended to the Caisses d’Epargne in 2021. Another innovation: a concrete solution to the scourge of cyberbullying, which affects 20% of young people, was provided by including psychological assistance in Caisse d’Epargne’s school and supplementary health insurance offerings.

As in previous years, the proposed contracts were again awarded in 2021. In non-life insurance, the new multi-risk home insurance offering, the result of the #INNOVE2020 program and common to the Banque Populaire and Caisse d’Epargne networks, is already among the best on the market and was awarded four Labels of Excellence. In personal protection insurance, Dossiers de l’Epargne also awarded three “Labels 2021” in the individual protection category to SECUR’Famille 2, Autonomis and Assurance Famille. In addition, the IMA PROTECT remote surveillance product, offered by the Banque Populaire and Caisse d’Epargne networks, was once again recognized by Capital Magazine. Lastly, the Insurance Business Unit was also rewarded with an Argus d’Or in the “open innovation” category for the work carried out with the start-up Zelros on the automation of medical screening.

The year 2021 was also marked by a strong commitment from employees to deal with the very significant surplus of activity caused by the health crisis and by the various climate disasters.

Groupe BPCE Insurance Business Unit also confirmed its status as pioneering 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.

The Payments Business Line

The Payments Business Line creates “payment as a service” solutions across the entire payment value chain: from issuance to acquisition to omnichannel to processing to employee benefits. It is backed by a robust technological base, highly innovative fintechs, and teams of recognized experts. The solutions are aimed at retail, professional, corporate and non-profit customers of Groupe BPCE networks, as well as retailers, banks and fintechs:

In 2021 the Payments Business Line continued its development, notably through the commercial activity of PayPlug, which recorded nearly 3,400 new customer signatures. Dalenys, whose offers are aimed at large e-merchants, also supported its customers in the DSP2 migration which imposes new rules such as strong customer authentication. The Banques Populaires expanded their range with the launch of an offer in conjunction with Dalenys.

With regard to its Employee Benefits and Services activities, an important step in its technological development was taken with the acquisition of the start-up Jackpot. Bimpli, a unique platform for employee benefits, was launched. Bimpli’s ambition is to support companies in the transformation of their social policy by offering a wide range of digital services capable of improving the daily lives of employees in both their professional and personal lives.

The Financial Solutions & Expertise Business Unit

The Financial Solutions & Expertise Business Unit (FSE) combines Groupe BPCE’s expertise in the financing, advisory and custodial services business lines. This Business Unit reflects the Group’s goal of focusing its activities on retail banking in a bid to accelerate its development for the benefit of its customers.

FINANCING BUSINESS LINES

BPCE Factor

BPCE Factor develops factoring solutions for companies of all sizes, covering their entire growth process (set-up, development, acquisitions, international expansion, etc.). In 2021, in a context of economic recovery and thanks to its commercial momentum, it will record an 11% growth in factored revenues.

A large part of its SME and professional customers can enter into a fully digitized relationship. BPCE Factor strives to offer a digital experience of the highest market standards with its all-digital offer, FlashFactures, which has a Net Promoter Score (NPS) of 56.

A satisfaction target confirmed for the 6^th consecutive year by Bureau Véritas Certification, which renewed BPCE Factor’s service certification and labeling. It was recognition for the high level of quality perceived by customers: 94% overall satisfaction and a Net Promoter Score of 26.

BPCE Financement

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

In 2021, with an amount of outstandings of €29.9 billion, up 8%, Groupe BPCE became the leading player in consumer loans in France⁽¹⁾. The year was marked by record commercial activity with financing totaling more than €14 billion, up 19% year-on-year. The level of customer satisfaction measured by the NPS also shows a strong increase over 2021 with an NPS of 38 for personal loans compared to 31 in 2020 and 7 for revolving loans compared to 1 in 2020.

Lastly, for customers of the Banques Populaires and the Caisses d’Epargne, BPCE Financement, is deploying the CZEN financing solution, which enables payment in three or four installments.

BPCE Lease

BPCE Lease offers a complete range of rental solutions: furniture and property leasing, long-term vehicle leasing, boating or automotive leasing, IT operational leasing, and renewable energy financing.

At the end of 2021, BPCE Lease and its subsidiaries saw their production increase by 22% and total assets of €15.72 billion, representing an inventory of approximately 198,000 contracts. A dynamic that concerns all business lines. BPCE Car Lease, the long-term automotive leasing subsidiary of BPCE Lease, recorded an increase of 22% in its orders, in a declining automotive market.

In property leasing, BPCE Lease increased its production by 35% in amount. In the real estate segment as well, BPCE Lease nearly €47 million in security trust operations, a solution launched at the end of 2020.

Lastly, with €633 million in arranged financing, BPCE Énergéco, the subsidiary dedicated to financing renewable energies, also had a very active year.

In 2021, the Long-Term Rental (LLD) offer for individual customers was launched and the corporate LLD service offering was enhanced with the financing of electric charging terminals and the launch of a solution for managing connected fleets and car-sharing.

Lastly, BPCE Lease launched the Lease Impact program, which aims to support Groupe BPCE’s customers in their energy transition by meeting their needs in terms of energy production, energy efficiency and green mobility.

CEGC

Compagnie Européenne de Garanties et Cautions (CEGC) offers a wide range of financial guarantees across all Groupe BPCE markets, including individual, professional and corporate customers, and the real estate, social economy and social housing sectors.

The real estate businesses recorded a high level of activity in 2021. In a French market that grew by 7.7%, CEGC guaranteed 303,000 home loans to individual customers produced by Groupe BPCE’s networks, for an amount of €47 billion, an increase of 11%.

The year was marked by the launch of a new guarantee offer for unpaid rents intended for property managers on behalf of their landlord clients. The data from the Green Weighting Factor^® was included in the criteria for granting financial guarantees to developers and loan guarantees to social housing players. Finally, the use of artificial intelligence techniques to respond quickly to borrowers has intensified. In 2021, nearly 50% of requests for home loan guarantees to individual customers reviewed by the Caisses d’Epargne and the Banques Populaires received an immediate response.

SOCFIM

Historically the market leader in real estate financing (developers, property dealers, development funds, etc.), SOCFIM covers the entire country and all asset classes: new and existing housing, managed housing (students and seniors), offices, retail and logistics warehouses.

In line with market trends, operations involving new uses (co-living, co-working, urban logistics, etc.) were developed, as were those aimed at “building the city on top of the city” (financing brownfields, recycling obsolete buildings) in a vision of sustainable real estate for which SOCFIM and its expert teams have implemented innovative financial engineering.

ADVISORY BUSINESSES

Pramex International

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). Originally related to the Banques Populaires, Pramex International recorded sustained activity in 2021 in its two core business lines: Corporate Management and M&A (merger-acquisition). Since 2020, the Caisses d’Epargne have benefited from the services of Pramex International, which they are gradually integrating into their activities.

BPCE Solutions immobilières

BPCE Solutions immobilières, a major player in real estate consulting in France, has three business lines: Expertise & Consulting, Residential, Investment & Leasing with revenue of €39.6 million in 2021 (vs. €30.4 million in 2020).

In 2021, it continued to grow steadily by strengthening its partnership with Groupe BPCE companies – mainly in the residential sector with revenue of €24.2 million, i.e. +43% compared to 2020 and in the Expertise division by continuing to win new external customers with revenue of €14.4 million, i.e. +20% compared to 2020.

CUSTODY BUSINESSES

EuroTitres

EuroTitres is the leading French provider of outsourced custody services on the retail market. As in 2020, EuroTitres recorded exceptional activity on the stock market in 2021, again thanks to the strong mobilization of individual customers but also due to the simplified public tender offer by BPCE for Natixis shares, which affected many savers of Groupe BPCE. At the end of December, 3,000,000 orders had been processed. A system for the exit from securities that have become ineligible for the PEA has been set up for the portfolios of the Group’s clients as part of the implementation of Brexit.

https://groupebpce.com/

“Investor Relations” section

Roland Charbonnel,

Head of Group Funding and Investor Relations

The second largest banking group in France, Groupe BPCE operates in all areas of banking, asset management and insurance, serving its 36 million customers in France and worldwide. Cooperative, it is owned by its nine million cooperative shareholders and is supported by its 29 regional banks (14 Banque Populaire banks and 15 Caisses d’Epargne), Natixis, Banque Palatine and Oney. The strength and durability of its model are based on balanced governance. The Group is thus focusing its strategy and actions on the long term, reconciling economic performance, social equity and environmental protection.

The Group’s companies are closely linked to their regions, are actively involved in the life of the city, and contribute more than 20% of the financing of the French economy. The Banque Populaire banks and the Caisses d’Epargne have often been at the forefront of social innovations that have marked the economic and social history of the country, through employee savings, financial education and low-cost housing. Today, the entire Groupe BPCE is committed to meeting the challenges of our time, first and foremost the fight against climate change. The transition to a low-carbon economy requires considerable levels of funding and support for all economic players in their own transition. The Group has mobilized and committed to making energy transition a priority in its BPCE 2024 strategic plan.

Its strong local presence puts Groupe BPCE in direct contact with major societal issues. It is thus a leading player in banking inclusion, whether in terms of preventing over-indebtedness or supporting micro-entrepreneurs, notably through partnerships with major networks in France. Its presence is particularly recognized among protected persons, vulnerable people and companies in difficulty. Groupe BPCE and its subsidiaries are actively working to promote greater social diversity by integrating young employees, some from underprivileged neighborhoods, and greater diversity by increasing the number of women in its governance bodies. Natixis has also committed to diversity by supporting the creation of the LGBT + All Equals network in France.

The nature of its business and its power mean that Groupe BPCE has a great responsibility when it comes to CSR issues. It is completely involved and puts its full capacity for action at their service.

In 2021, Groupe BPCE placed the climate and the "employee experience" at the heart of its new strategic plan, BPCE 2024. This plan highlights a strong environmental strategy combined with ambitious intermediate objectives and an HR strategy promoting the quality of life at work and the professional development of all employees. In addition, the Group’s CSR policy combines fundamentals that emphasize the overall consideration of our economic and social responsibility and respect for the principles that guide its approach.

In this context, Groupe BPCE’s CSR strategy has been overhauled and structured around three areas and twelve commitments:

Groupe BPCE’s CSR strategy and goals are carried out in compliance with business ethics. 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 a Group code of conduct and ethics approved by the Steering and Supervisory Board in 2018 and a rigorous tax policy with a tax code of conduct in 2021.

Through international and national memberships, Groupe BPCE acts in compliance with numerous international, national and working group commitments.

For several years, the Group and its subsidiaries have been committed to reinforcing their contributions to the UN sustainable development Goals (SDGs) and to increasingly contributing to the fight against climate change. The SDGs are a common language built around 17 global goals, broken down into 169 targets. Thus, Groupe BPCE’s CSR strategy is fully committed to integrating its SDGs in order to participate in the common journey to achieve a better and more sustainable future for all.

MEETING THE EXPECTATIONS OF CIVIL SOCIETY

BECOMING A MAJOR PLAYER IN THE ENVIRONMENTAL TRANSITION

DESIGNING THE FUTURE OF WORK

PUBLIC COMMITMENTS THAT MEET DEMANDING INTERNATIONAL STANDARDS

PARTICIPATION IN SECTORAL WORKING GROUPS

For several years, the Group has been particularly active in think tanks committed to the fight against climate change, sustainable finance, biodiversity and market issues.

SUSTAINABLE FINANCE

In 2021, Groupe BPCE participated in numerous working groups launched by the European Commission through technical consultations on the following topics (non-exhaustive list):

In addition to the European consultations, Groupe BPCE may be required to respond to the consultations launched by the French authorities concerning the transposition of European texts.

At the European level, Groupe BPCE is a member of various professional associations, and participates in specific working groups that European banking organizations have set up to help advance Sustainable Finance strategy. These include the European Savings Banks Group (ESBG) and the European Association of Co-operative Banks (EACB).

Groupe BPCE also took part in the sensitivity analysis exercise of the European Banking Authority (EBA) in connection with the Taxonomy, giving rise to a stress test carried out throughout the Paris financial center.

FIGHT AGAINST CLIMATE CHANGE

As part of its work within the working group of the Climate Commission of the French Banking Federation (FBF), which is chaired by the Chairman of the Management Board Laurent Mignon, Groupe BPCE participates in dialogs and discussions on:

In parallel with this work on the market, Groupe BPCE is committed to working alongside its peers. In July 2021, the Group joined the Net Zero Banking Alliance (NZBA), a financial initiative of the United Nations Environment Program (UNEP FI). This alliance between banking institutions is a decisive step in the mobilization of the financial sector to fight against global warming.

In addition, on the occasion of the Climate Finance Day of October 26, 2021, the FBF announced the commitment of the six largest French banks, including Groupe BPCE, to no longer finance dedicated projects and companies whose share of unconventional hydrocarbons in exploration and production (shale oil, shale gas and tar sands) would exceed 30% of their activity by January 2022. During 2022, the banks included in this working group will continue their work to promote the reduction of the use of these unconventional hydrocarbons.

BIODIVERSITY

Natixis, through its subsidiary Mirova, is part of the steering group of the Taskforce on Nature-related Financial risk and Disclosure (TNFD) initiative, whose work began in 2021 for two years. The TNFD is the result of a partnership between the Natural Capital Finance Alliance (NCFA), the United Nations Development Program (UNDP) and the World Wide Fund for Nature (WWF), with the support of the British government. With the same model as the Taskforce on Climate-related Financial Disclosures (TCFD), but making it possible to extend to nature-related issues, the TNFD will offer a framework to meet the measurement and data needs of financial institutions so they can better understand dependencies and their impacts on nature. The TNFD is intended to support the transition of the financial market by providing a framework for organizations to report nature-related risks and act according to their evolution, in order to divert global financial flows from negative activities for nature and redirect them towards activities that are positive for nature.

This working group addresses several issues:

Once adopted, the TNFD will enable financial institutions to manage the indirect impact of their investment and financing activities on nature, to reduce financial flows with a negative impact while promoting those with a positive impact.

TAXONOMY: PROMOTION OF A COMMON EUROPEAN LANGUAGE

Contextual elements: the valuation of assets eligible for the Taxonomy is an unprecedented exercise, the results of which depend in part on the interpretation of the regulatory texts by the institutions measuring them. These texts are backed by a recent regulation, some specifications having been published in February 2022. There are persistent inaccuracies in terms of application. Groupe BPCE therefore specifies that, while efforts have been made to comply with their requirements, the methods used are likely to change.

The objective of the Taxonomy Regulation (EU) 2020/852

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.

As a priority for action, it is committed to supporting all its customers in their own environmental transformation challenges and to making the environmental transition one of its main growth drivers as part of its BPCE 2024 strategic plan.

It is also committed to aligning its portfolios on a “Net Zero” trajectory by prioritizing the portfolios for which the bank can have the most significant impact, i.e. those in the most greenhouse gas-intensive sectors.

The European Taxonomy is a methodology for assessing the activities of a company in relation to environmental objectives, and more specifically in its current version, to mitigate and adapt to climate change.

These assessments are provided for by regulation in several phases.

For this first fiscal year according to the delegated act adopted in July 2021⁽¹⁾, the objective is to identify so-called “eligible” activities, that is, products or services that can potentially (but not necessarily) contribute to climate change mitigation or adaptation. For financial institutions, a ratio measuring the balance sheet portion of assets eligible for the Taxonomy is to be published.

In a second phase, the green assets corresponding to the activities said to be aligned with the Taxonomy will be assessed: they differ from those eligible by comparing the performance of these eligible activities with technical criteria and requirements in terms of respect for the environment and minimum social safeguards. These so-called aligned activities, which can be assessed in 2024 based on company data, will be published by BPCE and will enrich its internal climate measures and green commitments.

For Groupe BPCE, Taxonomy is an essential tool for increasing the transparency of climate measures and encouraging the development of companies’ green activities and their financing over time.

Also, while these first asset ratio assessments in their eligible versions do not reflect a real green measurement (as the “alignment” ratio aims for in 2024), they nevertheless constitute a first regulatory step that the Group supports in its publication efforts in terms of mandatory and voluntary declarations.

Framework of the exercise and result of the assessments of the eligible ratios of the taxonomy

Groupe BPCE publishes its eligibility ratio here for its activities as a credit institution.

The valuation was carried out on the data as of December 31, 2021 on the basis of the prudential consolidation scope, in a FINREP compliant environment, measured at gross book value. It does not take into account off-balance sheet exposures (financial guarantees and other off-balance sheet exposures).

In accordance with regulations, central governments, central banks and supranational bodies as well as financial assets held for trading are excluded from the numerator and denominator of the ratio.

Companies that are not required to publish non-financial information under directive 2013/34/EU (NFRD) and interbank demand loans are excluded from the numerator.

Mandatory publications

ELIGIBILITY RATIO RESULT

The proportion of exposures to economic activities not eligible for the taxonomy, in relation to the total exposures covered by the ratio, is 54%.

Most eligible assets includes outstanding home loans and loans to local authorities, loans to social housing and financing of automotive consumer loans. It should be noted that in this mandatory format, in the absence of data published by the companies on their eligible activities, the ratios cannot take into account their potential eligible activities⁽²⁾.

Methods and limits underlying the calculation:

DETAILS ON THE HEDGING OF OUTSTANDINGS

CALCULATION SCOPE⁽³⁾

EXPOSURES INCLUDED IN THE DENOMINATOR BUT EXCLUDED FROM THE NUMERATOR

Other clarification:

The proportion of exposures to financial and non-financial companies subject to Articles 19 bis and 29 bis of directive 2013/34/EU (NFRD), in relation to the total exposures covered by the ratio is 36%. For calculation purposes, this is the share of non-SME corporate customers in Europe.

VOLUNTARY PUBLICATION FOR THE BANKING BOOK

On a voluntary basis and in the interest of transparency, BPCE nevertheless supplements its publication by including in the calculation of the eligibility ratio the companies considered “eligible” on the basis of their NACE sector classification.

These are approximations, as the breakdown of activities between eligible and non-eligible companies is not based on data published by them.

Including in this framework the estimate of eligible corporate customers, Groupe BPCE's ratio of eligible economic activities to total exposures covered (by the ratio) is 54%.

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

The Banque Populaire banks, cooperative banks, expressed their “raison d’être” in 2019: Banque Populaire expresses its purpose - Fédération Banque Populaire (https://www.fnbp.fr/actualite/
banque-populaire-exprime-sa-raison-detre/)

In 2021, despite the ongoing health and economic crisis, the Banque Populaire banks maintained a strong relationship with their cooperative shareholders and their directors, who guarantee the vitality of their cooperative model. The 4.9 million cooperative shareholders are the foundation of the cooperative structure of Banques Populaires. They hold their share capital. 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 578,000 cooperative shareholders voted. The average total vote rate for the network is 12.3%.

To ensure the continuity of cooperation, online conferences and webinars have maintained the link between the bank and its cooperative shareholders. These latter enjoy access to information channels to keep up to date with news about their banks, including newsletters, magazines, and websites. A stakeholder listening tool “Le WOK Banque Populaire” was set up to enable cooperative shareholders to participate in the life of their bank. In 2021, more than 500,000 cooperative shareholders were invited to share their ideas on various topics such as “supporting young people in the face of the crisis” and “their commitment to their cooperative bank”. In addition, for the past five years, the Banque Populaire banks have been organizing “Faites de la coopération” (Cooperate), a week to raise awareness and discuss the cooperative model. It is part of Social and Solidarity-Based Economy (SSE) month. The program for the 2021 edition included communication tools, employee training (BDIGIT application) and tools explaining the cooperative model for advisors (money plan and Banque Populaire cooperative cheat sheet).

In 2021, the Banque Populaire network had 219 directors (and 20 non-voting members). They are business leaders, researchers and teachers involved in the economic life of their region.

To meet the regulatory requirements for training directors and evaluating the functioning of the Boards of Directors, 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

As the CSR & Co-operative Guidelines for 2018-2021 expire, the Caisses d’Epargne have defined a new roadmap for 2024. Several objectives have been set as part of the “Active cooperation” ambition, including a goal of rebalancing the age pyramid of cooperative shareholders and promoting membership among employees. 2021 was marked by the complete renewal of the cooperative governance chain of the Caisses d’Epargne.

The Caisses d’Epargne had a membership of 4.5 million cooperative shareholders at the end of 2021, the vast majority of whom were private individuals, spread across 218 local savings companies (SLEs), which constitute an intermediate level to strengthen local roots, proximity and the expression of members.

In 2021, the Caisses d’Epargne continued their efforts to get their cooperative shareholders more involved in the life of their bank as key stakeholders. They took action to ensure they had access to their services and kept them informed during the health crisis. They provide them with dedicated information and communication channels, newsletters, and meetings led by Caisse d’Epargne experts. The website www.societaires.caisse-epargne.fr underwent a complete overhaul in 2020, fulfilling its role as a single portal for information and access to the cooperative shareholders’ club.

In addition to these supports, some Caisses d’Epargne set up mechanisms for listening to cooperative shareholders, as well as actions to enhance leadership, such as web conferences. Some Caisses d’Epargne also implemented initiatives to raise employee awareness of the cooperative model, in particular during the welcome days for new members, in order to strengthen and rejuvenate cooperative shareholding. For more information: https://www.federation.caisse-epargne.fr/.

As part of the cooperative governance of the Caisse d’Epargne network, the Fédération Nationale des Caisses d’Epargne (FNCE), in conjunction with BPCE and the Caisses d’Epargne, supports and trains elected representatives in the exercise 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 (COS), 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 2021, the renewal of governance was a major institutional highlight, particularly in the organization of training and information sessions during the first year of office.

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.

KEY FIGURES

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.

Thus, 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.

Since January 1, 2019, Groupe BPCE has had a Climate Risks division within the BPCE Risk division. In 2020, dedicated risk correspondents were appointed in the risk departments of the Banque Populaire and Caisse d’Epargne networks, as well as in the Group’s subsidiaries. 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 is responsible for defining and implementing the climate risk monitoring system for all Groupe BPCE companies. The operational integration of this system in the establishments will make it possible to better integrate climate risks into the Group’s risk appetite.

The Climate Risk Committee, chaired by the Chairman of the Management Board, was created in 2020. This is a decision-making and monitoring committee that deals with climate issues from a cross-functional perspective for the Group and its various business lines. Among its responsibilities, it is in charge of examining the Group’s main existing or potentially emerging climate and environmental risk areas. It also builds scenarios and validates the climate stress test transition matrices to assess the resilience and vulnerability of the Group’s business model. By way of illustration, in 2021 the Climate Risk Committee approved the review of the work on climate risk in all its dimensions in order to provide a comprehensive view of its challenges.

CONTINUED WITHDRAWAL FROM GROUPE BPCE’S MOST EMITTING ACTIVITIES

In order to limit the climate impact of its financing, investment and Insurance activities, Groupe BPCE is withdrawing from activities with the highest emissions, framing this approach within appropriate exclusion policies.

Coal, which is responsible for around 45% of human emissions, is the leading source of global temperature rise. Accordingly, in accordance with its objectives in terms of combating global warming, Groupe BPCE has undertaken to gradually reduce its exposure to thermal coal to zero by 2030 for its activities in European Union countries and the OECD and, by 2040, for its activities in the rest of the world. This timeline is aligned with the International Energy Agency (IEA) sustainable development Scenario.

At the end of 2021, Groupe BPCE’s exposure to coal industry financing (0.14% exposure) were zero for thermal coal mine financing and reached a residual amount for coal plant financing and other coal-related infrastructure.

Groupe BPCE has also committed to no longer financing dedicated projects and companies whose share of unconventional hydrocarbons in exploration and production (shale oil, shale gas and tar sands) is higher than 25% of their activity, knowing that in December 2017, Corporate & Investment Banking had undertaken to stop financing the exploration and production of oil in the Arctic.

This commitment to the protection of the Arctic strengthens the position of Ostrum and Mirova (affiliates of Natixis Investment Managers), which have been at the head of a group of investors since 2016, signatories of a declaration calling for the protection of this area against oil exploration activities, as well as the respect of national commitments in terms of the fight against climate change in this region, which is particularly rich in hydrocarbons.

In October 2021, Groupe BPCE committed to reducing its exposure to hydrocarbon exploration and production activities by 15% by 2024 compared to the end of 2020.

IMPLEMENTATION OF SECTOR-BASED EXCLUSION POLICIES IN SENSITIVE SECTORS WITHIN THE GROUP’S BUSINESS LINES

INTEGRATION OF ESG CRITERIA INTO FINANCING ACTIVITIES: RETAIL BANKING AND CORPORATE & INVESTMENT BANKING

Within the retail banking scope, ESG criteria have been systematically incorporated into sectoral policies since 2018. The Non-Financial Risk Committee (CoREFi), made up of the Climate Risk, Credit Analysis and CSR departments, has been conducting reviews of all sectoral policies since March 2020 with a view to integrating these issues.

As part of these reviews, each business sector is assessed on the basis of criteria related to physical climate risks, transition risks and biodiversity. A sectoral classification follows from this assessment and identifies specific points of attention. These sectoral policies are intended to fuel exchanges, particularly when granting credit. The primary objective is to provide additional elements of analysis with regard to regulatory and market developments, to be able to better advise our clients, but above all to be aware of environmentally-friendly behavior in order to be able to support and promote exemplary activities. Since 2020, a non-financial note for the customer is, in certain cases, added to the analysis sheets in order to enrich the process of granting credit.

The review of climate and environmental issues comes from the analyses of CoREFi sector policies mentioned above. These elements will be used over time for the credit committees and counterparties of the entities and Groupe BPCE.

At the same time, tools to integrate ESG criteria within the bank have been deployed:

In Corporate & Investment Banking business lines, the consideration of ESG risks is part of a global approach involving business lines, CSR and control functions. This approach includes the development and implementation of CSR policies in the most sensitive sectors, the definition of excluded business sectors, the evaluation and monitoring of the ESG risks of transactions and counterparties via various tools and processes.

As a signatory of the Equator Principles, Corporate & Investment Banking 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. Corporate & Investment Banking has applied the amended version of the Principles (EP IV Amendment) since October 2020. More comprehensive criteria in terms of respect for human rights (including the rights of indigenous communities) and the analysis of physical and transitional climate risks are required. The financing granting process is enhanced by an in-depth analysis of the ESG impacts for each corporate via the ESR Screening tool (see section 1.3.2) and, more granularly for each transaction, on the environmental impacts thanks to the Green Weighting Factor tool.

INTEGRATION OF ESG CRITERIA INTO ASSET MANAGEMENT ACTIVITIES

The incorporation of ESG criteria is fully in line with the overall investment strategy of Natixis Investment Managers’ affiliates, which enables them to identify the risks or opportunities related to ESG issues and to assess how these issues may affect financial performance, particularly over the long term.

Many affiliates use internal models to assess the impact of ESG issues based on data from companies in which they invest, public institutions and other external organizations.

In 2021, Ostrum Asset Management strengthened its expertise in sustainable bonds (green bonds, social impact bonds, and sustainable bonds) through the development of the methodology for analyzing sustainability-linked bonds and the implementation of an analysis and rating tool. These new methodologies for assessing sustainability-linked bonds and transition bonds will be included in the tool from 2022. As of this year, Ostrum has also joined the principles of the ICMA (International Capital Market Association) and participates in various working groups, notably on impact reporting and social impact bonds.

Also this year, for example, Harris Associates increased the amount of ESG data available and facilitated access to it for its investment teams through the creation of an ESG dashboard accessible on their data platform. 2022 will be marked by the development of their internal ESG risk management system.

Alliance Entreprendre, an expert in private equity for SMEs and mid-sized companies, takes into account ESG criteria throughout the investment cycle and undertakes to systematically assess its investment targets on the basis of the relevant ESG criteria. These are discussed with the managers of the target companies and an ESG clause is systematically included in the shareholders’ agreements, mentioning in particular the commitment to send an annual assessment of the ESG indicators.

INTEGRATION OF ESG CRITERIA IN OWN INVESTMENT ACTIVITIES AND FOR INSURANCE ACTIVITIES

The ESG incorporation approach applied to financing and retail banking activities is being extended in own-account investment activities. An ESG analysis of bond portfolios has been offered to institutions since April 2020. The purpose of these analyses is to provide institutions with reliable information, based on the ratings assigned by the non-financial rating agency ISS ESG. This information enables institutions to better manage their portfolios and to be able to communicate on their incorporation of ESG criteria. Twenty-two institutions integrate ESG criteria upstream of their investment decision.

As part of its life insurance business, the risk management of the insurance division’s portfolio is based on a dual approach:

In addition to risk management, Groupe BPCE is committed to making a positive contribution to the sustainable development Goals for its Insurance activities. This commitment involves a selective ESG integration policy that enables improvements, based on Mirova’s ESG analysis (an affiliate of Natixis Investment Managers), to the ESG profile of investments under management mandates and in dedicated funds.

BEYOND THE CLIMATE, THE GROUP IS COMMITTED TO BIODIVERSITY….

Groupe BPCE is aware of the major challenge presented by the deterioration of natural capital and, as a bank, asset manager and insurer, it is committed to taking concrete action to preserve it. The Earth is currently facing a mass extinction of living species: more than 60% of the population of wild animals has disappeared in the last 40 years. One million animal and plant species are threatened with extinction out of the estimated eight million on the planet.

All of Natixis’ financing, asset management and insurance businesses have been involved in a cross-functional discussion on biodiversity issues since 2018, resulting in eight concrete commitments targeted 100% on its direct and indirect biodiversity impacts. The commitments are part of Natixis’ participation in the Act4nature international initiative, and their SMART nature (specific, measurable, additional, relevant, time-bound) was validated by a multi-stakeholder committee made up of 16 partners including several environmental NGOs. Natixis was the first bank involved in the Act4nature international initiative to communicate individual SMART commitments in June 2020:

By making these commitments, Natixis has made biodiversity issues central to its CSR system, along with climate change. Aware that reducing its indirect impact is an important lever for contributing to the preservation of natural capital, Natixis puts biodiversity at the heart of its discussions with all of its customers and stakeholders. This approach is part of a more global action to support its customers in their environmental transition. Details of Natixis’ individual commitments are available on this link.

With regard to the integration of biodiversity into the dialog with public authorities, Natixis committed to “La Charte Objectif 100 hectares”: the City of Paris and its partners mobilized to revegetate 100 hectares of built-up area in the capital by 2020 (roofs, facades and green walls), one third of which is dedicated to urban agriculture.

INCORPORATION OF SPECIFIC BIODIVERSITY CRITERIA INTO FUNDING DECISION-MAKING PROCESSES

The Green Weighting Factor (GWF) internal assessment tool makes it possible, among other things, to assess the impact of financing on biodiversity in the sectors for which this issue is material, as well as the impact of dedicated financing (financing of projects or assets) located in Key Biodiversity Areas.

Corporate & Investment Banking can thus integrate an in-depth analysis of the impact on biodiversity into its project financing operations, and continue to further take into account the issues related to the preservation of natural capital in all its activities.

In accordance with the Equator Principles, Natixis requires its clients to study all the risks and potential impacts of their projects from an environmental, social, health and safety perspective, and to implement all the necessary means to minimize and correct potential impacts. Damage to biodiversity is an integral part of this vigilance. Groupe BPCE’s risk policy is applied in the banks and at the central level in the sector policies. These include a section dedicated to the impacts on biodiversity.

ASSET MANAGEMENT INITIATIVES TO TAKE BIODIVERSITY MORE INTO ACCOUNT IN THE BUSINESS

As part of our commitment to support innovative environmental solutions, Natixis IM recently completed a minority investment with Iceberg Data Lab, a financial technology company that develops assessment tools and provides environmental data solutions to financial institutions.

Faced with the growing demand from financial institutions and their stakeholders for greater transparency on the impact of portfolios on the climate and the environment, Natixis IM and its subsidiary Mirova, as well as AXA IM, Sienna Capital and Solactive will support the global expansion and product development of Iceberg Data Lab. The latter aims to bring to market intelligent solutions based on scientific and biodiversity data. It was recently selected by a consortium of investors, including Mirova, to develop a tool allowing investors to measure the impact of their investments on biodiversity.

Ossiam also worked closely with the company to develop the Food for Biodiversity ETF using Iceberg Data Lab’s biodiversity footprint indicator. In addition, following the development of an investment strategy that minimizes the portfolio’s biodiversity footprint, Ossiam committed to integrating biodiversity at the heart of its activities by signing the Finance for Biodiversity commitment.

In addition:

Groupe BPCE plays a major role in the economic and social development of France. As a socially responsible employer, it obviously respects:

Since 2020, we have been experiencing an unprecedented situation linked to the health crisis: a human challenge for all teams which has led to the acceleration of the implementation of new digital tools and to rethinking the organization of work and its practical aspects. This situation of crisis and “constraints” has enabled a new collective experience: new digital tools, new way of managing remote teams, all with increased vigilance in terms of data security.

Our 100,000 employees have all remained very engaged and committed to their internal and external customers. They have all demonstrated an exceptional ability to adapt to maintain and develop our customer service.

In this context of acceleration, the future of work and the HR roadmap for the 2024 strategic plan are emerging:

GROUP HEADCOUNT

Key figures:

Complete quantitative human resources indicators for Groupe BPCE are available at https://groupebpce.com/en/csr/employees⁽¹⁾

UNVEILING THE POSSIBILITIES: AN EMPLOYER BRAND REVISITED

Vitality, freedom, commitments: Groupe BPCE affirms the pillars of its identity as an employer

To reinforce the Group’s reputation among candidates and employees, the Group renewed its employer brand in 2021, with a brand platform developed in addition to and in line with existing brands. The objective of Groupe BPCE employer brand is to create strong, structured, and unique positioning.

https://groupebpce.com/en/all-the-latest-news/news/2021/vitality-freedom-and-commitment-groupe-bpce-confirms-the-pillars-of-its-identity-as-an-employer

Groupe BPCE recruits nearly 6,000 candidates each year. The Group is strengthening the following areas to attract the right profiles in a competitive environment:

TARGETS

Our recruitment mainly concerns the commercial sector and, in particular, the following groups:

Special attention is also paid to IT and Data profiles.

Our recruitment policy is focused on skills. It contributes to the development of a diversity of profiles (by degree, gender, origin, etc.).

A STRONGER DIGITAL PRESENCE

Groupe BPCE continued to develop its presence on social media by regularly communicating about its recruitment events, broadcasting business videos and promoting work-study programs.

The number of subscribers is constantly increasing:

ENSURE THE RECRUITMENT OF YOUNG PEOPLE EVEN IN TIMES OF CRISIS

The crisis did not prevent companies from pursuing their policy of recruiting work-study students and of offering professional training contracts.

In 2021, the Group set up a new recruitment website with better visibility for the business lines and more powerful testimonials. A page is dedicated to work-study programs and young graduates.

https://recrutement.bpce.fr/

The “Innove ta banque” competition, the flagship event for students and work-study students, also continued with great success: 73 participating schools, 990 candidates and 255 applications submitted.

https://www.agorize.com/fr/challenges/innove-ta-banque

For its part, Natixis maintained its commitment to youth employment during the health crisis and took part in around fifty events to raise awareness of its businesses among young people in 2021: student forums (such as Trium 2020), initiatives with partner schools (e.g. the Chaire “Business analytics and future banking” with HEC & Polytechnique, the launch of a student lab with Ecole 42, a workshop on the meaning of work with HEC, etc.).

INTEGRATE AND RETAIN NEW EMPLOYEES

The newcomer pathway (PNE) is the preferred support system offered by the Group. It places the employee on a professionalizing and adapted learning and progress path.

It is intended to cover all the skills required (in terms of knowledge, know-how and soft skills) and useful to:

Integration pathways are increasingly digitized, but with dedicated in-person events.

INTRODUCTION

THE GROUPE BPCE CODE OF CONDUCT AND ETHICS

Groupe BPCE adopted a “Group code of conduct and ethics” in 2018. It was reviewed by the Cooperative and CSR Committee then approved by the Executive Management Committee and the Supervisory Board.

The code is based on international values and standards. It includes a message from Executive Management and sets out the Group’s ethical standards in three areas: the interests of customers, employer responsibility and social responsibility, with practical business-oriented examples.

The Code applies to all members of staff in all Groupe BPCE entities. In addition, Natixis also has a code of conduct which was published in early 2018. It defines the main principles on which the company’s employees can rely in their relations with Natixis’ various stakeholders: clients, teams, shareholders, and society as a whole.

For more detail, here are the links where they can be found:

GUIDING PRINCIPLES

These rules of conduct are illustrated with real-life situations that may be experienced by any employee, manager, director or other stakeholder. The scenarios enacted serve as benchmarks to help them discern the right decision to make in the exercise of their profession.

The code of conduct and internal policies and procedures provide clear instructions on how to behave, but they cannot provide a solution for all situations. Employees must exercise their judgment to make the right decision, drawing on the principles set out in the code of conduct.

If they have any doubts about what they are about to do, employees should ask themselves the following questions:

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 have been learned. This training is mandatory for all Group employees and for all new hires. As of December 31, 2021, 93.6% of registered employees, including those of Natixis, had completed the training.

Another training course entitled “The Essentials of Ethics” completes the program. 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, monitors 36 indicators collected from all Group entities. It is presented twice a year to the Supervisory Board’s Cooperative and CSR Committee (fifth edition, presented in December 2021). It collects data and information on the deployment of the system, incidents, disciplinary sanctions and types of breaches.

ALERT SYSTEM

Groupe BPCE has a whistleblowing system specifying the procedure applicable in all Group entities, as provided for by the law of December 9, 2016 (Sapin 2 law) and the decree of November 3, 2014 on the internal control of banking sector companies. The current whistleblowing procedure applies to all internal employees, as well as to external and occasional staff, who may resort to the procedure if they become aware of a crime, offense, serious violation of the law, serious threat to, or infringement of, the public interest or of any behavior or situation that violates the code of conduct. Groupe BPCE entities protect whistleblowers.

The details of the whistleblowing process and the procedure to follow as a whistleblower are available on the Group’s website: Ethics and compliance: Groupe BPCE’s actions and commitments. The contact details of a hotline are listed in the procedure. Whistleblowers can make an anonymous report if they prefer. Finally, in order to protect whistleblowers, all reports are treated confidentially.

The majority of Groupe BPCE operates in French, but the procedure is also available in English. As this is an important subject, communication campaigns are carried out to remind people of the existence of this system, notably on the Yammer employee exchange site.

In 2021, the Group updated the systems governing “Whistleblowers”, “Conflicts of interest”, and “Gifts and benefits”:

In addition, the Group is finalizing a standard summarizing all of the rules relating to ethics. This latter document defines the missions of the players, presents the main elements of the regulatory framework, and identifies the elements of the system relating to ethics, including control.

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 states that “Businesses should work against corruption in all its forms, including extortion and bribery”.

ANTI-CORRUPTION MEASURES

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 procedures make it possible to comply with the requirements introduced by Article 17 of the Law 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 framework of controls involved in the prevention and detection of fraud and acts of corruption or influence peddling was formalized in 2020. In this context, donations, sponsorships and patronage are handled with due care.

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.

Natixis’ corruption prevention policy is available on its website https://www.natixis.com/natixis/jcms/ala_5383/en/compliance

FIGHT AGAINST LAUNDERING AND PREVENTING INTERNAL FRAUD

Financial security covers anti-money laundering and terrorist financing (AML-CFT) measures as well as adherence to international sanctions aimed at individual persons, entities or countries.

Groupe BPCE works to prevent money laundering and terrorist financing through:

The declarations are made in respect of money laundering or terrorist financing and/or tax fraud. The Group risk classification incorporates the issue of “at-risk” countries, whether in terms of money laundering, terrorism, tax fraud, or corruption, as well as the politically exposed status of the client or its beneficial owners, for legal entities. The transactions of high-risk customers are subject to particular vigilance. The Group’s system was strengthened in 2018 with the introduction of a framework and automated scenarios (generating alerts), regularly adapted to changes in risks related to the financing of terrorism.

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

STRENGTHENING OF THE SYSTEM IN 2021

Over the past fiscal year, Groupe BPCE has stepped up its oversight system to ensure compliance with international financial sanctions and embargoes in order to become more effective. After the creation of a central alert processing team in 2020, the management system was enriched with face-to-face training on how to handle sanctions alerts and improved tools for filtering customers and operations.

The tool for detecting politically exposed persons has been optimized to improve efficiency and reliability.

As part of the program initiated by the Group in 2020 to update customer knowledge based on the risks of money laundering and terrorist financing, a remediation action on the incomplete files of high-risk customers was carried out in 2021.

Intra-group information exchanges were extended to the various categories of customers with a high AML/CFT risk.

A certification module dedicated to the professional expertise of financial security employees has been rolled out.

The exceptional context of the health crisis linked to the Covid-19 pandemic made it possible to test business continuity and remote work arrangements, and did not lead to a reduction in AML/CFT vigilance on customers or on operations.

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. 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:

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’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 pays its fair share to public finances. In France, for fiscal year 2021, the amount of income tax amounted to €1,946 million, plus bank taxes and contributions amounting to €535 million.

In 2021, a Eurotax Observatory study published on September 21 examined the operations in low-taxed states of 36 European banking groups over the period 2014-2020. It noted 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%.

In 2021, 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 and included large-scale financial transactions. Groupe BPCE was the first bank to be admitted to this new system.

TAX CODE OF CONDUCT

Groupe BPCE has adopted a tax code of conduct describing the principles and general framework that guide all Group entities with regard to their own taxation and that applicable to their customers, and within the framework of their relationship with the tax authorities. The code will be distributed in 2022 and will apply to all Group employees.

EU DIRECTIVE “DAC 6”: NEW TAX TRANSPARENCY OBLIGATIONS

Groupe BPCE is committed to implementing international and European regulations aimed at reducing the impact on government budgets of organizations taking advantage of more favorable regulations.

Thus, in the course of 2021, Group entities established in a European Union country completed the deployment of procedures that will enable them to comply with the obligation imposed by European regulations to detect and, if necessary, report cross-border arrangements that are somewhat aggressive from a tax point of view.

The deployment concerns both operations carried out by customers and those implemented by the Group’s entities themselves.

LIST OF NON-COOPERATIVE STATES AND TERRITORIES (ETNC)

France has, by an order of February 26, 2021 published in the Official Journal on March 4, 2021, updated its list of non-cooperative states and territories (hereafter “ETNC”).

The new list includes the following 13 jurisdictions:

Anguilla, British Virgin Islands, Panama, Seychelles, Vanuatu, Fiji, Guam, American Virgin Islands, American Samoa, Samoa, Trinidad and Tobago, Palau, and Dominica.

The new decree excludes the Bahamas and Oman from the list. However, Dominica and Palau are included in the ETNC list.

It should be noted that the French list of ETNCs is now identical to the EU list with the sole exception of the British Virgin Islands, which remain on the French list but not on the EU list.

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

FINANCING OF PUBLIC LIFE AND REPRESENTATION OF INTEREST

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 to candidates and political parties set up by Article 28 of act No. 2017-1339 of September 15, 2017, for Trust in Political Life.

REPRESENTATION OF INTERESTS

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 with which its public contacts, and the various financial market associations of which it is a member, are required to comply.

In addition, in France, BPCE is registered in the “AGORA” Lobbyist Register, in accordance with the legal obligations arising from Law No. 2016-1691 of December 9, 2016, Regarding Transparency, the Fight against Corruption, and Modernization of Economic Life, as well as the directives of the High Authority for Transparency in Public Life (HATVP). In this context, Groupe BPCE reports on its actions, commitments and expenses to the HATVP with the information required by law (https://www.hatvp.fr/fiche-organisation/?organisation=493455042).

Lastly, at the European level, Groupe BPCE is also listed in the European Commission transparency register. As a reminder, this register is a database that lists organizations that attempt to influence the law-making and policy implementation process of the EU institutions. https://ec.europa.eu/transparencyregister/public/consultation/displaylobbyist.do? id = 179370613236-62

This section explains the methodology applied by Groupe BPCE in its CSR reporting.

Sustainable development indicators based on the Global Reporting Initiative (GRI) guidelines are used to complete the non-financial performance statement, in line with the ESG risk analysis performed by the Group in 2021 (see Chapter 2.1.4). The indicator guidelines were also updated to incorporate regulatory changes, the expectations of our stakeholders (rating agencies, investors, NGOs, etc.), feedback from CSR officers in charge of reporting, and the recommendations of the independent third party for fiscal year 2021.

ENVIRONMENTAL INDICATORS

Environmental transition indicators are business line indicators collected from centralized databases by network. Indicators on outstanding renewable energy loans are collected from the Group Risk division.

The environmental indicators linked to the carbon footprint are collected from the CSR correspondents of the entities, in collaboration with their general resources correspondents via the SPIDER data entry tool.

The methodological approach adopted for the construction of the carbon footprint is that of the ISO 14064 standard. Data are collected annually by each entity’s CSR officers, and are reported in the COGNOS tool, rolled out in 2015.

Most of the emissions factors are based on those set by the French Environment and Energy Management Agency (ADEME) and are updated annually. In accordance with the general principles of carbon accounting, the integration of emission factors specific to Groupe BPCE is encouraged in the following cases:

Work to refine the carbon footprint data was carried out in 2021, mainly on the inclusion of teleworking. Other adjustments to the data of the entities were made mainly to the purchasing and energy items (emission factor of the overseas agencies). The data for 2019 and 2020 were aligned accordingly.

2019 and 2020 data from the Banque de Savoie (a subsidiary of BPAURA) and the data from Oney France were also included in the Group’s carbon footprint.

HUMAN RESOURCES INDICATORS

No major changes were made to the human resources indicators so as to ensure stability and to allow for comparison.

Human resources data (excluding training) are extracted from two centralized information systems managed by the Group HR Data Management and Information Systems division (HRIS). They are “My Link RH” for companies in the Caisse d’Epargne network, and the “Perse” data center for all other entities.

The data extracted from the two information systems is verified following a regular control process at Group level, according to the human resources indicators published in the registration document.

Not all of the Group’s workforce is included in the HRIS. In order to obtain the total workforce for the Group, the Group social management system collects workforce data from the companies concerned and a manual consolidation is done. The workforce excluding Group HRIS represents 7% of the Group’s total workforce.

Permanent contracts include work-study contracts with an indefinite term. Fixed-term contracts include fixed-term work-study contracts (professionalization contracts and apprenticeships). Employees included in the headcount at December 31 of each year include those departing on that date and those whose contracts have been suspended.

New hires data refer to new hires on permanent and fixed-term contracts signed between January 1, and December 31, including work-study contracts (professionalization and apprenticeships).

Departures data include staff on permanent contracts leaving between December 31 of the previous year and December 30 of the current year broken down by reason: dismissal, resignation, departure during a trial period, mutually-agreed termination, transfer within the Group and retirement. The departure rate corresponds to the number of departures among permanent staff in year N divided by the total number of permanent staff at December 31 in year N-1.

Since the migration of the Caisses d’Epargne to the My Link HR information system, the Group HRIS is unable to count the movements of employees on fixed-term contracts who have had several successive contracts. In 2021, around ten Caisses d’Epargne were affected by this anomaly.

In view of this difficulty, indicators relating to hiring and departures are only published for permanent contracts (work-study students included).

Entries and exits in the context of transfers between different Group companies are taken into account in the new hires and departures totals for the year.

Absenteeism figures are calculated at December 31 of year N, based on absences recorded at that date and recorded in the HR information system at the time of data extraction for the scope under review.

Absenteeism is calculated as per the Group human resources data. It corresponds to the ratio between the number of days of absence in year N and the number of days due to be worked in the same year.

The “pandemic” absenteeism rate takes into account all absences linked to the Covid epidemic (illness-pandemic, medical emergency absences, partial activity, childcare, etc.).

Since 2020, the indicators relating to training have been extracted from the “Click and Learn” training information system and concern all attributable training sessions allocated to the plan for year N and validated by the training departments of the companies in the scope in question on the date of data extraction.

SOCIETAL INDICATORS

Societal indicators are mainly indicators related to the funding granted to local authorities, social housing players and the social and solidarity economy. Data are extracted from centralized databases. Their accuracy is regularly verified at Group level. Indicators related to patronage, microloans and cooperative identity are provided by the two networks’ federations and by the Group’s outside partners (Adie, France Active, Initiative France). Procurement indicators are provided by BPCE Achats.

FINANCING THE ENERGY TRANSITION

The scope adopted is that of the BPCE 2024 strategic plan to integrate the new offers already launched in 2021.

The indicator “Amount of financing of the energy transition (annual production)” for 2021 includes PTZ loans, ECOPTZ loans, co-ownership ECOPTZ loans, consumer loans (SD works loans, energy renovation loans, SD car loans) and PROVAIR for companies.

The changes concern:

Consumer loan financing can be used to finance the installation of photovoltaic panels on the customer’s home.

This indicator does not include the financing of renewable energy projects such as wind farms or photovoltaic fields.

BUSINESS MODEL

The Group’s business model is presented in the Chapter 1. It presents our main activities, our business model, what sets us apart and our ambitions in line with the BPCE 2024 strategic plan. The business model is updated each year as necessary.

REPORTING STRUCTURE

CSR reporting is organized by the Group CSR division, which coordinates the required tasks each year (updating the guidelines, indicators and user guides; advising the banks on the drafting of their own annual CSR report; etc.).

Like every year, it worked with the Group’s operational divisions (IT, human resources, Real Estate & Logistics, Procurement, etc.) and federations (FNBP, FNCE) in order to make better use of centralized databases.

More specifically, to prepare the 2021 non-financial performance statement, the Group CSR division worked with the Group Risk division and its regional functions.

Various initiatives were taken in this respect in 2021, in collaboration with all of the contributors to the non-financial performance statement, to facilitate the appropriation of this new process by all Group entities:

REPORTING TOPICS

The following topics are considered relevant in terms of the bank’s indirect impacts: circular economy, reducing food waste, combating food poverty, improving animal welfare and ensuring responsible, fair, sustainable food supplies.

These topics are not addressed in specific paragraphs in this report but are covered by the bank’s ESG risk analysis procedures. For its lending business, these topics are covered in sector policies. For investment and asset management activities, they are covered by the ESG ratings methodologies for fund management.

ROLE OF METHODOLOGY TOOLS

Risk analysis matrix

The matrix used to rate the 15 non-financial risks provides a rating system for gross risks based on their frequency and severity over a three-year period.

User Guides

The user guide for all contributors to Group CSR reporting was updated for the 2021 fiscal year. It specifies the following for the Universal Registration Document (URD) and for each entity (annual management report or URD):

This guide also relies on a CSR reporting standard that specifies all of the indicators published, their definitions, their units, the corresponding GRI reference, their sources, how they are calculated and collected, and examples of controls to carry out.

The Group carbon footprint user guide was also updated in 2021. The guide is intended to promote the carbon-review system. The purpose of this guide is to:

Reporting period

The published data covers the period from January 1, 2021 to December 31, 2021. Where physical data are not comprehensive for the period, contributors make approximate calculations to estimate the value of the missing data from average ratios provided by Groupe BPCE (in the user guides) based on FTEs and/or the surface area covered. The contributors review the estimates used and send their comments along with the information provided and approved by the Group.

Comparability

This year, Groupe BPCE chose to only report figures for a single fiscal year for some indicators which underwent a major change in definition compared to 2020 and some that were newly published in 2021.

Controls

The “Non-financial information quality control framework” defines the organization of the control system for non-financial information within Groupe BPCE, and describes the main policies in place on this subject. It applies to all Groupe BPCE entities in the consolidated scope: the central institution, its direct and indirect subsidiaries, all BPCE affiliates and their subsidiaries.

Each entity is responsible for the accuracy of its CSR data. The same applies to Groupe BPCE’s operational divisions.

At Group level, all data collected are verified and subject to a careful review of units and data consistency. Contributors are asked for an explanation where figures appear unjustified.

If any data published in the management report for the previous year prove inaccurate, a correction is made with an accompanying explanation on the bottom of the same page.

For the fiscal year ended December 31, 2021

To the General Meeting of Shareholders,

In our capacity as Statutory Auditors of BPCE SA, designated as an independent third party, accredited by COFRAC under No. 3-1048 (Cofrac Inspection accreditation, No. 3-1048, available at www.cofrac.fr) and in the process of adapting our management system as part of the evolution of our accreditation procedures decided by COFRAC (transition from ISO 17020 to ISO 17029), we carried out work aimed at formulating a reasoned opinion expressing a conclusion of limited assurance on the historical information (recorded or extrapolated) of the consolidated non-financial performance statement, prepared according to the procedures of the entity (hereinafter the “Guidelines”), for the year ended on December 31, 2021 (hereinafter the “Information” and the “Statement”, respectively), presented in the Group management report in accordance with the legal and regulatory provisions of Articles L. 225-102-1, R.225-105 and R.225-105-1 of the French Commercial Code.

Conclusion

Based on the procedures we have implemented, as described in the section entitled “Nature and scope of the work”, and the information we have collected, we have not identified any significant anomaly that would call into question the fact that the non-financial performance statement complies with the applicable regulatory provisions and that the Information, taken as a whole, is fairly presented in accordance with the Guidelines.

Comments

Without calling into question the conclusion expressed above and in accordance with the provisions of Article A. 225-3 of the French Commercial Code, we make the following comment:

As stated in the methodological note, the social indicators are not exhaustive outside the Group’s workforce and cover significantly different scopes depending on the topic.

Preparation of the Statement

The absence of a generally accepted and commonly used reference framework or established practices on which to evaluate and measure the Information allows the use of different but acceptable measurement techniques that may affect comparability between entities and over time.

Consequently, the Information must be read and understood with reference to the Guidelines, the material elements of which are presented in the Statement (or available on the website or on request at the entity’s head office).

Limitations inherent in the preparation of information related to the Statement

The Information may be subject to uncertainty inherent to the state of scientific or economic knowledge and the quality of the external data used. Some information is sensitive to the methodological choices, assumptions and/or estimates used in its preparation and presented in the Statement.

Entity liability

It is incumbent on the Management Board

The Statement was prepared by applying the entity’s guidelines as mentioned above.

Responsibility of the Statutory Auditor appointed as independent third party

Based on our work, our responsibility is to express a limited assurance conclusion on:

As it is our responsibility to form an independent conclusion on the information as prepared by management, we are not authorized to be involved in the preparation of such information, as this could compromise our independence.

It is not our responsibility to comment on:

Regulatory provisions and applicable professional doctrine

Our work described below was carried out in accordance with the provisions of Articles A. 225-1 et seq. of the French Commercial Code, the professional doctrine of the Compagnie Nationale des Commissaires aux Comptes relating to this intervention in lieu of an audit program and the international standard ISAE 3000 (revised).

Independence and quality control

Our independence is defined by the requirements of Article L. 822-11-3 of the French Commercial Code and the French Code of Ethics for Statutory Auditors (Code de déontologie). In addition, we have put in place a quality control system that includes documented policies and procedures to ensure compliance with applicable legal and regulatory texts, ethical rules and the professional doctrine of the Compagnie nationale des commissaires aux comptes related to this intervention.

Means and resources

Our work involved the skills of five people and took place between November 2021 and February 2022 over a total period of fifteen weeks.

To assist us in conducting our work, we referred to our Corporate Social Responsibility and sustainable development experts. We conducted around ten interviews with the people responsible for the preparation of the Statement, representing executive management, administration and finance, risk management, foundations, human resources and the environment.

Nature and scope of procedures

We have planned and carried out our work taking into account the risk of material misstatement of the Information.

We believe that the procedures we have conducted, exercising our professional judgment, enable us to formulate a conclusion of moderate assurance:

The procedures implemented as part of a moderate assurance are less extensive than those required for a reasonable assurance carried out in accordance with the professional doctrine of the Compagnie Nationale des Commissaires aux Comptes. A higher level of assurance would have required more extensive audit work.

Dear shareholders,

In addition to the management report and in accordance with Article L. 225-68 of the French Commercial Code, this report by the Supervisory Board contains information on:

This report was reviewed by the Appointments Committee and the Remuneration Committee on February 10, 2022, then approved by the Supervisory Board at its meeting of February 10, 2022.

The external Statutory Auditors will issue a specific report, appended to their report on the annual financial statements, attesting to the provision of other information required by law in the report on corporate governance (Article L. 225-235 of the French Commercial Code).

In preparing this report, BPCE referred to the Corporate Governance Code for listed companies published in December 2008 and revised in January 2020 by the Association française des entreprises privées (AFEP – French Private Companies Association) and the Mouvement des entreprises de France (MEDEF – French Business Confederation), hereinafter referred to as the AFEP-MEDEF Code, including the October 2008 recommendations on executive pay, as set out in Article L. 225-68 of the French Commercial Code.

Only certain provisions were not followed, insofar as they are not deemed to apply to BPCE’s operating procedures as the central institution of a cooperative group and its equal ownership by the Banque Populaire and Caisse d’Epargne networks, which is reflected in the composition of its Board. These provisions were as follows: terms of office, the proportion of independent directors on the Supervisory Board and its committees, Board member ownership of a material number of shares and the publication of the CEO pay ratio.

Regarding terms of office, unlike the maximum four-year term recommended in the AFEP-MEDEF Code, the statutory term of office of BPCE Supervisory Board Members is six years, i.e. the maximum permitted by law. The benefit of a four-year term, as presented by the AFEP-MEDEF Code, is that it gives shareholders sufficiently frequent opportunity to provide an opinion on Board Member performance. However, this is unnecessary for BPCE, as its shareholders are limited to Banques Populaires and Caisses d’Epargne, which are already amply represented on the Supervisory Board as voting or non-voting directors. Accordingly, a shorter term of office would not substantially change the composition of the Supervisory Board. In addition, BPCE staggers reappointments, renewing the terms of office of half of the Supervisory Board members every three years, in order to avoid mass reappointments and promote a smooth Board member reappointment process. This gives shareholders sufficiently frequent opportunity to provide an opinion on Supervisory Board members, as recommended in the AFEP-MEDEF Code.

Regarding Supervisory Board member ownership of a material number of shares, BPCE’s Articles of Association take into account the fact that, in accordance with act No. 2008-776 of August 4, 2008, Supervisory Board members are no longer required to own shares in the company. As a result, BPCE Supervisory Board members do not own a material number of shares and are not shareholders in a personal capacity, but the two categories of shareholders are represented through their appointment, which ensures that the company’s interests are respected.

Concerning the proportion of independent directors on the Board and its committees, BPCE does not follow the recommendation of the AFEP-MEDEF Code, under which independent directors must represent half of the members of the Boards of companies that are not under control, as defined by Article L. 233-3 of the French Commercial Code. In fact, this recommendation is not compatible with Article L. 512-106 of the French Monetary and Financial Code, which stipulates that the representatives of cooperative shareholders proposed by the Chairmen of the Steering and Supervisory Boards of the Caisses d’Epargne and the Chairmen of the Boards of Directors of the Banques Populaires account for a majority of the Supervisory Board of BPCE. In addition to this legal rule, good governance rules result from Groupe BPCE’s unique structure: a balance of power must be maintained, as well as balanced representation of the Banque Populaire and Caisse d’Epargne networks. However, this organizational structure does not compromise the quality of the work and discussions of the Board, an objective of the AFEP-MEDEF Code recommendation.

However, BPCE wishes to demonstrate the independence of the members of its Supervisory Board representing the cooperative shareholders proposed by the Chairmen of the Steering and Supervisory Boards of the Caisses d’Epargne and the Chairmen of the Boards of Directors of the Banques Populaires. The report “Coopératives et mutuelles: un gouvernement d’entreprise original” [Cooperatives and mutual insurance companies: original corporate governance], drafted within the framework of the French Institute of Directors in January 2006, explains why the elected directors of the cooperative companies that are the Banques Populaires and the Caisses d’Epargne fully meet the definition of “independent director”. Thus, the question of “independent directors” concerns a specific type of company, which is the listed company. […] In cooperative enterprises, the form of government is radically different. […] The legitimacy and control of a mutual manager, and therefore his independence, depend on the office he holds through his election. Removing a director from the electoral process would dissociate him from the interests of the organization and its cooperative shareholders.

From another perspective, it is a fact that the directors of cooperatives and mutual societies commit themselves out of conviction and not out of financial interest. They devote a significant portion of their time and energy to their responsibilities as directors. They are wide open to the local, nonprofit and/or political world. These are all characteristics that make them truly independent directors, an independence that does not have to be called into question, but is continually reinforced by an authentic democratic process.

For Supervisory Board Meetings and committee meetings, BPCE does not apply the recommendation on the organization of an annual meeting without the presence of executive company directors. However, the deliberations of the Supervisory Board and the opinions of the Board committees concerning the executive company directors take place without their presence.

In addition, the Fédération Nationale des Banques Populaires and the Fédération Nationale des Caisses d’Epargne, bodies that organize discussions, hear ideas and provide representation, each hold annual meetings bringing together all the Chairmen of the Boards of Directors and the Chief Executive Officers of the Banques Populaires and all the Chairmen of the Boards of Directors and Supervisory Boards of Caisses d’Epargne without the presence of Statutory Auditors and the company directors of BPCE. These meetings, which guarantee the free expression of all participants, who represent BPCE’s shareholders, promote strategic discussions and, accordingly, protect the interests of the institutions they represent.

Furthermore, regarding information on company director pay, BPCE does not apply the recommendation that stipulates that information on pay ratios should be published, thereby enabling comparison of company director pay and employee pay. In fact, the legislator’s aim in drafting this legal provision, now taken up by the AFEP-MEDEF Code recommendation, which is to enable shareholders or investors of publicly-traded corporations to assess company director pay against the company’s performance, is not relevant in light of BPCE’s capital structure, under which the Banques Populaires and Caisses d’Epargne together hold all of the share capital and voting rights.

Finally, with the exception of the CEO pay ratio, BPCE formally adheres to and implements the AFEP-MEDEF Code recommendations on executive pay.

STATEMENT OF NON-COMPLIANCE WITH THE AFEP-MEDEF CODE⁽¹⁾

DUTIES AND POWERS

The Supervisory Board performs the duties attributed to it by law. It carries out all checks and controls it deems appropriate and may request any documents it regards as expedient in fulfilling its mission.

The Supervisory Board:

In addition to these powers, the Supervisory Board has the authority to:

OWN POWERS

FOR DECISIONS SUBJECT TO A SIMPLE MAJORITY

The following operations proposed by the Management Board must receive prior authorization from the Supervisory Board, acting by simple majority of its present or represented members:

DECISIONS SUBJECT TO A QUALIFIED MAJORITY VOTE (13 OF 19 MEMBERS)

The following operations proposed by the Management Board are subject to the prior authorization of the Supervisory Board and a favorable vote from at least thirteen of its nineteen present or represented members:

INTERNAL RULES

The Internal Rules of the Supervisory Board, adopted at the Board Meeting of July 31, 2009 and amended at the Board Meeting of December 20, 2018, form the Supervisory Board’s Governance Charter, which sets out its internal operating procedures, notably for the purpose of ensuring that governing bodies interact efficiently and operate smoothly.

The Internal Rules enhance the quality of the work done by Supervisory Board members by promoting the application of corporate governance principles and best practices in the interest of ethics and efficiency.

Their purpose is also to supplement the Articles of Association, notably by:

The Supervisory Board’s Internal Rules are available on the BPCE website: https://groupebpce.com/investisseurs/informations-reglementees/autres-informations

ETHICS AND COMPLIANCE CHARTER

The Supervisory Board of BPCE adopted an Ethics and Compliance Charter for its members at its meeting of June 22, 2016. The Ethics and Compliance Charter is divided into four main Chapters that set out good governance principles, in addition to reiterating several laws and regulations.

Chapter 1 covers the Board Members’ professionalism, as expressed in different ways:

Chapter 2 covers ethics, as expressed by:

Chapter 3 covers confidentiality:

Chapter 4 covers conflicts of interest:

ACTIVITY OF THE SUPERVISORY BOARD

In accordance with Article 25.1 of the Articles of Association, the Supervisory Board meets as often as the company’s interests, laws and regulations require, and at least once every quarter in order to examine the Management Board’s quarterly report. Board Meetings may be convened by its Chairman, its Vice-Chairman or by one half of its members and take place at the registered office or any other location stated in the notice of meeting.

In accordance with Article L. 823-17 of the French Commercial Code, the Statutory Auditors are invited to Board Meetings examining full-year and half-year financial statements.

The BPCE Supervisory Board met 15 times between January 1 and December 31, 2021. In 2021, the average attendance rate for Supervisory Board Members was 96.84%. In addition to the topics regularly discussed – quarterly reports of the Management Board, related-party agreements, approvals of executives, current events and other matters for information – the main topics discussed during the Board Meetings were as follows:

GOVERNANCE – INTERNAL OPERATING PROCEDURES OF THE BOARD

STRATEGIC OPERATIONS

FINANCE

AUDIT – COMPLIANCE – RISKS

CSR

Depending on the type of matters submitted to the Supervisory Board, discussions were held and decisions made on the basis of the reports presented by the relevant Board Committees.

At the meeting on May 19, 2017, the Supervisory Board set the pay for the Chairman and Vice-Chairman of the Supervisory Board as well as the terms for distributing pay for attendance at meetings among the Supervisory Board members. These terms and conditions were reviewed by the Supervisory Board at its meeting of March 26, 2020.

The remuneration package for the members of the BPCE Supervisory Board was set at €800,000 for fiscal year 2021 and subsequent years by the Ordinary General Meeting of May 29, 2020. This pay is detailed in the statement regarding pay collected by the non-executive corporate officers of BPCE.

Aside from the Chairman, who receives annual fixed pay, Supervisory Board members are paid based on their attendance at meetings.

PAY GRANTED TO THE CHAIRMAN OF THE SUPERVISORY BOARD

PAY GRANTED TO SUPERVISORY BOARD MEMBERS

Pay granted to the Vice-Chairman of the Supervisory Board:

Other members of the Supervisory Board:

ADDITIONAL PAY GRANTED TO SUPERVISORY BOARD COMMITTEE MEMBERS

Pay granted to the Chairman of the Audit Committee:

Other members of the Audit Committee:

Pay granted to the Chairman of the Risk Committee:

Other members of the Risk Committee:

Pay granted to the Chairman of the Appointments Committee:

Other members of the Appointments Committee:

Pay granted to the Chairman of the Remuneration Committee:

Other members of the Remuneration Committee:

Pay granted to the Chairman of the Cooperative and CSR Committee:

Other members of the Cooperative and CSR Committee:

As a reminder, the Chairman and Vice-Chairman of the Supervisory Board do not receive any pay for participating in the Cooperative and CSR Committee.

PAY GRANTED TO NON-VOTING DIRECTORS

Pursuant to Article 28.3 of the Articles of Association, the Supervisory Board has resolved to compensate non-voting directors by making a deduction from the pay for attendance at meetings allocated to Supervisory Board members at the General Shareholders’ Meeting.

Non-voting directors receive:

RULES GOVERNING PAY GRANTED TO THE MEMBERS OF THE SUPERVISORY BOARD

Attendance fees were eliminated by Article 185 of the PACTE act (act No. 2019-486 of May 22, 2010), which replaced them with “pay” that may be paid to directors and members of the Supervisory Board of a French limited liability company (société anonyme).

The change in legal terminology has no impact on the tax or social security charges applicable to the sums paid to directors and members of the Supervisory Board.

As such, any references to “attendance fees” below should be construed from a legal point of view as “pay.”

Attendance fees are subject to single mandatory withholding tax at the global rate of 30%, consisting of a non-discharging flat 12.80% of the income tax plus social security contributions at the global rate of 17.20%.

Taxpayers may, if they so choose, opt for the progressive income tax scale instead of the flat 12.80% when filing their tax return. This option can be used for the full amount, provided that it applies to all income and gains that fall within the scope of the single flat-rate withholding tax, which are collected or earned during a single year by all members of the tax household.

The following taxation conditions apply:

OTHER PAY

Other pay consists of total pay for attendance at meetings received by corporate officers in respect of their duties on the boards of Group companies during the period in question.

Each payment relates to the corporate officer’s presence at Board Meetings and is calculated on the basis of the total budget for attendance at meetings set by each company’s General Meeting.

TABLE ON PAY RECEIVED BY BPCE’S NON-EXECUTIVE CORPORATE OFFICERS FROM JANUARY 1 TO DECEMBER 31, 2021 (AMF TABLE 3)