Groupe BPCE and BPCE scopes of consolidation

The scope of consolidation of both groups, organized around the central institution, is presented in the diagram below.

In addition to BPCE, Groupe BPCE includes the Banques Populaires, the Caisses d’Epargne and their respective subsidiaries.

BPCE includes BPCE SA and its subsidiaries. The main difference in terms of consolidation perimeter stems from the contributions of the parent companies, which do not contribute to BPCE’s net income.

1.1.1   BP-1 — General basis for preparation of the sustainability statements

Groupe BPCE has prepared its sustainability report in accordance with European Sustainability Reporting Standards (ESRS). These standards provide a comprehensive framework for the disclosure of non-financial information on environmental, social and governance issues.

The Group’s sustainability report is based on a double materiality assessment, which takes into account both the impact of Groupe BPCE on the environment and society, and the influence of changes in the environment and society on the company’s performance. This approach takes into account the expectations of stakeholders, in particular employees, investors, customers, cooperative shareholders and the communities in which the Group operates. It results in a list of impacts caused by Groupe BPCE’s activity, and of risks and opportunities (IRO) related to environmental and societal changes.

To prepare this report, Groupe BPCE has collected data on a consolidated basis and across its value chain. This sustainability report is audited as required by the regulations with a limited level of assurance.

Scope of the sustainability report

The scope of consolidation used for this sustainability report is identical to that of Groupe BPCE’s consolidated financial statements. All entities included in the IFRS (International Financial Reporting Standards) consolidation scope of Groupe BPCE are also included in this sustainability report.

The institutions included in Groupe BPCE’s consolidation, permanently affiliated with BPCE in accordance with Article 10 of Regulation (EU) 575/2013 (CRR) and exempted from the individual and consolidated disclosure obligation in terms of sustainability are the following:

Exclusions from the reporting scope by family of indicators are indicated in the description of each indicator.

Option to omit specific disclosures

Groupe BPCE has not made use of the option that allows it to omit certain disclosures relating to intellectual property, know-how or the results of innovations. This option is provided for in Section 7.7 of ESRS 1: Classified and sensitive information, and information on intellectual property, know-how or results of innovation.

1.1.2   BP-2 — Disclosures in relation to specific circumstances

1.1.2.1   TIME HORIZONS

In most cases, the material impacts, risks and opportunities have been assessed in the short, medium and long term. To obtain forward-looking information on Groupe BPCE’s material impacts, risks and opportunities in its sustainability reports, the Group has adopted the general principles as defined in Section 6.4 of the ESRS 1 section, namely:

• 1 year as short term (annual financial statement presentation period);
• between 1 year and 5 years as medium term;
• more than 5 years as long term.

When the time horizons deviate from these general guidelines, this information is communicated at the same time as the relevant information concerning the specific material subject. During the preparation of this sustainability report, forward-looking estimates and assumptions were made. The results observed may differ from these estimates and assumptions.

1.1.2.2   VALUE CHAIN ESTIMATION

The indicators must cover the entire consolidated scope. However, for the calculation of greenhouse gas emissions under ESRS E1-6 (greenhouse gas emissions), the indicator is calculated over an extended scope. Scope 3, category 15 emissions relate to the value chain, in particular financed emissions.

For the calculation of Scope 3 category 15 emissions on the banking book, greenhouse gas data come from several sources:

purchase of supplier data (Carbone4, Trucost, CDP);

• data collected from the Group’s customers (DPE); and
• public databases (Centre Scientifique et Technique du Bâtiment).

When data is not available, the Group uses sectoral intensity estimates: either through extrapolation or using a proxy defined through PCAF.

1.1.2.3   SOURCES OF ESTIMATION AND OUTCOME UNCERTAINTY

This report, known as the Groupe BPCE sustainability report, was prepared in accordance with the legal and regulatory requirements resulting from the transposition of the European Directive on the disclosure of information on companies’ sustainability (Corporate Sustainability Reporting Directive or “CSRD Directive”). This first year of application is characterized by uncertainties about the interpretation of the texts, which are generalist and cover all sectors of activity but do not specify a specific framework for banking and financial business models. There is also the absence of established practices or comparative information and certain data, in particular within the “value chain”.

In this context, Groupe BPCE has endeavored to apply the normative requirements set by the ESRS, as applicable at the date of the sustainability statement, based on the information available within the timeframe for its preparation, by doing its best to reflect its role as a universal bank-insurer, as well as its various business models.

For the double materiality analysis and, in particular, that relating to its value chain, Groupe BPCE encountered limitations relating to the maturity of its valuation methodologies and the availability of data. As presented in Section 1.5.1.1 on the Environment (E), we considered that only the issue of mitigation and adaptation related to climate change is material within the meaning of the standard. The limitations relating to the market information and methodologies available at this stage did not make it possible to characterize the Nature ESRS’s materiality within the standard’s meaning, which led the Group to assess these environmental issues as non-material. This assessment was carried out based on the definitions of the standard, and the methodologies available to assess and carry out the rating exercises. This assessment can be explained, in particular, by the absence of a consensus on robust methodologies developed on the topics in question and of relevant and appropriate data which would make it possible to establish a link between the impact or risks for Groupe BPCE regarding these topics through its value chain. In view of Groupe BPCE’s continuous improvement approach to these environmental issues, the work and ongoing changes in international methodologies, the standards that are being put in place, the best market practices that are emerging and information and data from its customers, which should gradually become available, this double materiality analysis may change in the coming years. The dual materiality analysis, the results of which are presented in this report, aims to qualify the impacts, risks and opportunities as described in the CSRD standard: this analysis only meets the needs of sustainability reporting and not the analysis of factors risks presented in the chapter on risk management.

For the data points presented in this report, the BPCE Group used methodological options that it deemed relevant and made estimates for many data points, particularly concerning the various activities of its value chain. The data, analysis, and studies carried out do not guarantee that expectations and targets will be achieved: they are based on objectives, commitments, estimates, assumptions, standards, and methodologies under development and currently available data, which continue to evolve and develop. Some of the information contained in this document has been obtained from public sources or from sources that appear to be reliable or from market references: the BPCE Group has not independently verified them. In addition, Groupe BPCE notes that the information expected in terms of sustainability is based on so-called “agnostic” European standards (ESRS), which are generalist and do not reflect the specificities of the financial sector. As a result, certain data items deemed irrelevant or not applicable, given Groupe BPCE’s business models and value chain, have not been produced. The same applies to certain data points relating to the Taxonomy Regulation.

Regarding the climate change mitigation and adaptation transition plan, in its transition plan, Groupe BPCE distinguishes between actions relating to its own operations and the targets and actions that it has set itself in order to contribute to the decarbonization of the economy by supporting its customers. The actions described present, in particular, the achievements and roadmap for the actions that seem to impact the downstream value chain. The Group’s transition plan describes past, current and future efforts to align its financing, investment and insurance portfolios with scientifically established trajectories aimed at achieving global carbon neutrality by supporting its customers with their environmental transition. This report does not quantify the effects of decarbonization levers or future estimates of total financed emissions. Indeed, the actions undertaken by the Group cannot replace those of individual customers, companies or States that it supports with the transition, and the transition of the economy to a low-carbon economy depends on many parameters external to Groupe BPCE.

As regards the assessment of greenhouse gas emissions, as a service company, the Group emits a limited level of CO2e in terms of its own operations, including by integrating the upstream value chain (purchases, including those related to IT and technological investments, mobility including business trips, etc.) and the travel of its customers to its branches or business centers. Most of Groupe BPCE’s GHG emissions come from financed emissions and are subject to a normative calculation for category 15 of the emissions of the downstream “investment” value chain, otherwise known as “financed emissions”, aimed at attributing to the financial institution a portion of the CO2 emissions of its financed customers or securities in which it invests. This calculation takes into account the scopes 1-2-3 of customers, which therefore also include the emissions of their value chain, and leads to a maximum calculation. It is estimated that the financed emissions can be, on average, three times the same greenhouse gas emissions for portfolios of exposure to companies in the same value chain. For this sustainability statement, the Group considered the mandatory categories of financial assets provided for in the Greenhouse Gas (GHG) protocol for calculating financed emissions. The scopes, methodologies used and the main assumptions and data sources are detailed in the paragraph relating to (E1-6) “Gross Scopes 1, 2, 3 and Total GHG emissions”.

With regard to Taxonomy, the assumptions used and limitations are detailed in Chapter 2.1 Indicators of the European taxonomy on sustainable activities.

Groupe BPCE believes that the expectations reflected in these forward-looking statements are reasonable; however, they are subject to numerous risks and uncertainties, are difficult to predict, generally outside of the control of Groupe BPCE, sometimes unknown, and may lead to results or cause events to unfold significantly differently from those expressed, implied, or anticipated by the aforementioned information and forward-looking statements.

1.1.2.4   CHANGES IN PREPARATION OR PRESENTATION OF SUSTAINABILITY INFORMATION

As for all French companies, the sustainability report for the 2024 fiscal year is the first such report produced by the Group. Consequently, no change in the definition or calculation of metrics, including those used to set targets and monitor progress towards their achievement, is to be reported.

1.1.2.5   REPORTING OF ERRORS IN PRIOR PERIODS

As indicated above, since this exercice is the first, comparative data with previous periods are not presented. The reporting of errors in previous periods does not extend to the reference periods preceding this first year of application of the sustainability standards by the company. Furthermore, no significant error related to the previous Green Asset Ratio (GAR) period was identified.

1.1.2.6   DISCLOSURES STEMMING FROM OTHER LEGISLATION OR GENERALLY ACCEPTED SUSTAINABILITY REPORTING PRONOUNCEMENTS

With regard to risk management, Groupe BPCE has defined sustainability risk as a risk factor. The chapter on environmental, social and governance risks under Pillar III ESG describes how the Group defines and manages these risks. This chapter also contains an overview of the impact of climate and environmental risks on other types of risks. Further details on the methodologies and management used for traditional types of risks, such as credit risk, market risk, operational risk and liquidity risk, are provided in Chapter 7 - Risk factors and management.

In addition, the elements relating to the eligibility and alignment of the Group’s portfolio as defined in Regulation (EU) 2020/852 and supplemented by Delegated Regulations (EU) 2021/2178, 2021/ 2139 and 2023/2486 are included in Section 2.1. Indicators of the European Taxonomy on sustainable activities.

1.1.2.7   INCORPORATION BY REFERENCE

In order to avoid duplication, ESRS 1 allows the incorporation of parts prepared in other documents, such as the management report or the Universal Registration Document, by means of a simple mention, provided that this information has equivalent characteristics, particularly in terms of reliability. This generally concerns the parts relating to the description of the company’s activities and strategy, its governance, remuneration policies, risk factors and the Duty of Care. The ESRS believe that it is imperative to ensure and explain the consistency between the sustainability report and the financial statements, by paying particular attention to significant amounts, assumptions and projections. The amounts considered as material from the financial statements must be accompanied by a reference, although the presentation of a reconciliation in the form of a comparative table between the amounts of the sustainability report and those of the financial statements remains optional.

At Groupe BPCE level, the following information is incorporated by reference:

Groupe BPCE is a cooperative full-service bank and insurance Group serving its customers, cooperative shareholders, territories and the economy. Its cooperative model is inseparable from the history of its two historical networks, Banque Populaire and Caisse d’Epargne. These roots, which forge its identity, also condition its performance, both financial and non-financial.

Since its origin, Groupe BPCE has been rooted in a humanist aspiration: making people a core priority, giving everyone the means to save money and finance their projects, and playing a pioneering role in regional development. This DNA, supported by century-old brands, has been embodied at every stage of its history:

• 1818: creation of the first Caisse d’Epargne et de Prévoyance to promote, collect, and manage the general public’s savings;
• 1878: creation of the first Banque Populaire, founded by and for entrepreneurs to help finance their projects;
• 1919: creation of Crédit National, from which Natixis originated, to finance the reconstruction of the French economy;
• 2009: creation of Groupe BPCE through the combination of the Banque Populaire and Caisse d’Epargne groups, sharing common values of solidarity and proximity.

Thanks to its unlisted cooperative nature, which enables it to invest to meet the challenges of tomorrow, the Group’s action is part of the long term and provides local and concrete responses to the transformations of the economy and society. Its sustainable model is based on a positive financial trajectory and economic footprint contributing to both an environmental and societal impact. After fifteen years of transformation and simplification, Groupe BPCE is today a unique and solid group, 100% cooperative and bringing together 9.8 million cooperative shareholders.

Cooperative shareholding, one of the pillars of the cooperative model

By holding the company’s capital through cooperative shares, customers become cooperative shareholders and actively participate in the life, ambitions and sustainable development of their bank, with the aim of implementing a fairer and more inclusive company that is more democratic and guided by the public interest.

• The 9.8 million cooperative shareholders of the Banque Populaire and Caisse d’Epargne networks hold 100% of the capital of the Banques Populaires and the Caisses d’Epargne (through the intermediary of the local savings companies [LSC] for the Caisses d’Epargne). Their representatives sit on the Boards of Directors of the Banques Populaires and on the Steering and Supervisory Boards of the Caisses d’Epargne.
• The 14 Banques Populaires and the 15 Caisses d’Epargne, all with firm roots in their regions, hold 100% of the capital of BPCE, the Group’s central institution.

A regional cooperative model

A fundamental characteristic of its identity, the local presence of the Banques Populaires and the Caisses d’Epargne enables the Group to be attentive to everyone and understand the expectations of society. The Group transforms this proximity into a capacity for innovation to serve regional growth. By acting alongside local players (local authorities, associations, business networks, educational and university communities, etc.), Groupe BPCE brings this proximity to life:

• by making use of a short circuit of money. Local savings and results finance projects on this same scale, purchases are mainly made from local suppliers, and the Group creates jobs as close as possible to the regions;
• by promoting local ecosystems and dialog with its stakeholders such as chambers of commerce and industry, professional associations, social and solidarity-based economy players, NGOs and associations. Aware that solutions to social and environmental challenges require acting together, it stands alongside those who come together to take action.

Cooperative performance to ensure long-term growth: VISION 2030

Strong and proud of its many faces, Groupe BPCE has built itself around solid and complementary brands: Banque Populaire, Caisse d’Epargne, Natixis CIB, Natixis IM, Oney, Banque Palatine, with full-service regional institutions with differentiating expertise. The societal project that guides their activities defines the way in which the Group conducts its business. Coupled with its regional cooperative model, these brands contribute to the Group’s strengths, resources and stability.

With its VISION 2030 strategic project, the Group reaffirms the societal ambition of its activities by placing the cooperative dimension at the heart of its growth. It is now managed on the basis of a “cooperative performance”; both financial and non-financial, with an environmental and societal impact, and is part of a long-term perspective reconciling robustness, subsidiarity and impact.

Robustness

By being unlisted the Group is protected from any speculation, reserves are indivisible and the value created is distributed fairly among stakeholders. A portion of the surpluses is reinvested in the future of the Group’s companies to develop them and pass them on to future generations, and a portion is paid to the cooperative shareholders as well as used for the local development of the regions.

This model results in regular and low-volatility profitability, a moderate risk appetite and high solvency. The Group thus distinguished itself in Europe, where it maintained some of the highest solvency requirements.

Subsidiarity

Groupe BPCE’s decentralization and regional presence are real assets for supporting transitions and lasting transformation of society; they are the guarantors of rapid decision-making, as close as possible to the regions.

Impact

With its VISION 2030 strategic project, the Group aims to “make impact accessible to all”: this is the meaning of ‘impact for all.’ Its generalization is based on three main principles:

• the impact for all clients: individual clients for their energy renovation projects, corporate clients for their transition plans, local authorities in support of their policies;
• impact for all territories and the society: by enabling local players to join forces, with the help of the Group’s cooperative shareholders and developing regional initiatives;
• impact for all employees and boards of directors: by deploying an Impact Inside operation and by mobilizing 100% of Groupe BPCE’s employees, companies and governing bodies around ESG issues.

Groupe BPCE is convinced that it is a model in line with society’s expectations, whose changes it has always supported.

The philanthropic engagement and solidarity and sponsorship actions of the Banques Populaires and the Caisses d’Epargne

Banque Populaire network

Since 1992, the Fondation Nationale Banque Populaire, an instrument of sponsorship for the 14 Banques Populaires and their cooperative shareholders, has promoted individual initiative and supported, over the life of their projects, talented, creative people with an entrepreneurial spirit and a taste for innovation in three areas: classical music, disability and arts and crafts.

In 2024, the Fédération nationale des Banques Populaires endowment fund continued its support for ADIE, a national and regional association that finances and supports micro-entrepreneurs. Supplemented by the action of each of the Banques Populaires in the regions, Banque Populaire (excluding CASDEN) is once again in 2023 the first financial partner of ADIE with €47.7 million, which financed 10,000 microloans and contributed to the creation or maintenance of 12,200 self-employed and salaried jobs, in addition to skills sponsorship, honor loans, and other training support or Créadie Awards.

In addition to sponsorship, they are involved in actions in favor of civil society. They are highly involved in supporting business creation, integration (through microloans in particular) and solidarity, and actively support education and research. In addition, Crédit Coopératif and its foundation are mainly focused on supporting and promoting the social and solidarity-based economy. CASDEN Banque Populaire naturally favors education and research.

The impact of the sponsorship of the 14 Banques Populaires is one of the components measured each year via the Banque Populaire Cooperative and Societal Footprint (ECS). Based on ISO  26000 (the leading international standard for CSR), this footprint identifies and values in euros the CSR and cooperative actions implemented within each bank for the benefit of society, employees and customers, cooperative shareholders and suppliers. These actions go beyond regulations, excluding commercial, and traditional banking activity. In 2023, the cooperative and societal footprint (ECS) shows that the Banques Populaires network - composed of 12 regional Banques Populaires, CASDEN Banque Populaire and Crédit Coopératif -carried out 6,434 actions for the benefit of society and the regions, for a total amount of €194.6 million. There has been a sharp increase in the number and amount of ECS actions supported.

Caisse d’Epargne network

Created by philanthropists, the Caisses d’Epargne have been working to promote social cohesion and the fight against exclusion since their inception. They are among the leading corporate sponsors in France.

The Fédération nationale des Caisses d’Epargne has adopted CSR and Cooperative Guidelines that provide a shared framework for the actions of the Caisses d’Epargne around four ambitions: be a key player in the transformation of the regions and the local economy (local footprint), pursue the continuous improvement of ESG policies and their integration into all business lines for more impact (overall performance), encourage employees and cooperative shareholders to become cooper’actors (active cooperation) and anticipate societal needs to build solutions that contribute to progress (societal innovation).

The purpose of the endowment fund of the Caisse d’Epargne network constituted by the FNCE, is to encourage and support actions of general interest aimed at combating exclusion and poverty, particularly in banking and financial situations, and to support solidarity actions and assistance programs. It also supports the Finances et Pédagogie association, which deploys educational programs on money issues throughout the country. It also supports other large structures such as the Fondation Belem, which is recognized as a public utility, whose purpose is to promote France’s maritime past and to preserve France’s last large ship of the 19th century, which has been classified as a historic monument since 1984. Lastly, it has a €200,000 fund that responds quickly to natural disasters.

The 15 Caisses d’Epargne have their own sponsorship strategy in their regions. In 2024, sponsorship represented a total of €20.8 million and 1,290 local projects were supported, mainly in the field of youth, solidarity and sport.

1.3.1   SBM-1 - Strategy, business model and value chain

1.3.1.1   SUSTAINABILITY-RELATED STRATEGY

In 2024, Groupe BPCE rolled out its strategic project VISION 2030, a growth project at the service of its customers and their support in the face of the challenges of the environmental, demographic, technological and geopolitical changes.

The priority given to climate in its latest strategic project has been renewed and integrated into the Impact strategy, with an extra-financial trajectory that includes fifteen key impact indicators. This prioritizes the expansion of impact solutions to all clients of the group, accelerating across all ESG dimensions

Thus, sustainability, both environmental and societal, is at the heart of the Group’s strategy.

1.3.1.1.1 Sustainability-related strategy

A Group with “positive impact”⁽¹⁾

VISION 2030, Groupe BPCE’s new strategic project outlines the major priorities it has set for itself in order to build a growth project to serve its customers, in a society marked by four major transitions: environmental, demographic, technological and geopolitical.

Faced with this situation, Groupe BPCE is mobilizing its local and regional presence, its business lines and expertise, to enable its customers, cooperative shareholders and employees to assert their power to act and to trust in the future.

The cooperative nature of the Banques Populaires and the Caisses d’Epargne, combined with the banks’ strong local presence, have made Groupe BPCE a financial player which has notably committed to the decarbonization of the economy in recent years. Groupe BPCE’s global business lines - Natixis Corporate & Investment Banking (Natixis CIB) and Natixis Investment Managers (Natixis IM) - are positioned as key global players in transitions.

Environmental impact

Faced with the climate emergency, Groupe BPCE’s approach sets out to ensure the rapid implementation and rollout of measures designed to mitigate and adapt to the already tangible environmental and socio-economic impacts. Making “the impact accessible to all”⁽²⁾ means raising awareness and providing support to all its clients in the environmental transition by providing them with expertise, advisory services, and comprehensive solutions.

Building on the scenarios defined by science, the BPCE Group and its businesses position themselves as facilitators of transition efforts, with a clear and ambitious goal: to finance a carbon-neutral economy by 2050 by taking action today.

The Group’s approach is based on its cooperative business model: a presence in local communities and a commitment to society geared to financing the economy.

• Impact solutions

For individual clients: providing support for energy renovations and home adaptations addressing aging and reduced autonomy by offering financing solutions and by mobilizing Groupe BPCE’s role as a housing operator, trusted third party along with its network of partnerships:

• by offering an “Advice and Sustainable Solutions” tool in partnership with ADEME, making it easy for clients to calculate their carbon footprint but also to benefit from advice and assistance for energy renovation work, for decarbonized mobility or green investments;
• by providing support at every stage of energy renovation projects for individual homes and condominiums: energy assessment, search for grants, guarantee of successful completion of work, with financing pathways tailored to each situation;
• by increasing the volume of financing for the energy renovation of buildings.

1. Terminology for the strategic project VISION 2030: https://www.groupebpce.com/en/the-group/strategic-plan/
2. VISION 2030 strategic project terminology: https://www.groupebpce.com/le-groupe/plan-strategique/

For BtoB customers: supporting the transition of the business models of its clients, from SMEs to the largest international companies. The Group engages with its clients through dedicated dialogue and sector-specific expertise to integrate ESG issues according to the size of the companies and their economic sectors, particularly in energy infrastructure, transportation, waste management and treatment, etc. Sustainable solutions also exist for investor clients with a range of responsible investments and placements: sustainable development passbook accounts, funds with a sustainable investment target, theme-labeled funds, etc..

• Support for the evolution of the energy mix: faced with the climate emergency, the priority is to accelerate the advent of a sustainable energy system:
  • by positioning itself among the world leaders in debt project financing in the renewable energy sector;
  • by increasing its financing dedicated to the production and storage of green electricity;
  • by providing advice about capital raising processes to its clients commanding leading positions in the infrastructure and equipment sector related to energy transition as well as innovative and high-growth companies in the same sector;
  • by advising its customers on energy transformation projects in their financing or capital raising processes;
  • by supporting the reindustrialization of regions and energy sovereignty;
  • by setting up teams of experts dedicated to low-carbon energies (solar, wind, electrolysis, etc.) and critical metals.
• Alignment of its financing and insurance portfolios with trajectories compatible with the objectives of the Paris Agreement:
  • by developing carbon emission measurement systems;
  • by developing its system for identifying and managing physical and transitional climate risks affecting both its clients and its own activities, on the basis of a continuous improvement approach;
  • by gradually withdrawing from the most-carbon emitting activities, in particular through adapted ESG policies.

In this context, the Group has joined the Net Zero Banking Alliance initiative of the United Nations Environment Program (UNEP FI), and has a decarbonization ambition for the most carbon-emitting sectors.

• Active and innovative issuer in sustainable finance: in its VISION 2030 strategic project the Group has set itself the target of issuing more than five green, social or health funding instruments per year, using all the debt instruments at its disposal.

Societal impact

The Group is a leading financier in the Social and Solidarity Economy sector, local authorities and a major player in social housing, social entrepreneurship and microcredit.

• A player in the territories and regions of the world where it operates: Groupe BPCE plays a major role in local ecosystems promoting territorial cohesion, supporting numerous initiatives in favor of social inclusion and the reduction of inequalities:
  • the Banques Populaires and the Caisses d’Epargne are key players in the dynamic development of our territories, notably by financing the construction or renovation of infrastructure and facilities necessary for education, health, and mobility. They are the leading providers of private funding for local authorities and the hospital sector;
  • on a global scale, Natixis Investment Managers and Natixis Corporate & Investment Banking are developing their Asset & Wealth Management and Corporate & Investment banking business lines in over 40 countries, in line with international commitments in terms of investment and financing activities.
• Committed to supporting local and national initiatives:
  • the impact of the sponsorship activities of the 14 Banques Populaires is measured annually through their Cooperative & Societal Footprint metric. This footprint identifies and values in euros the CSR and cooperative actions implemented within each bank;
  • the 15 Caisses d’Epargne have rolled out their Utility Contract in all regions of France: 100% cooperative, 100% regional and 100% useful for the economic, social and environmental development of the territories.

Transforming Groupe BPCE

In order to support the transitions of its clients in accordance with the best available standards, Groupe BPCE has launched an internal transformation plan entitled ‘Impact Inside’. In order to expand its impact solutions to its clients and speed up its progress in all the different aspects of ESG, Groupe BPCE has undertaken a transformation of all its companies at every level. It mobilizes its governance and employees, which it trains in ESG issues, and also acts on its own activities by reducing its carbon footprint.

1.3.1.1.2 Sustainability-related targets

Among the strategic priorities of VISION 2030, Groupe BPCE is renewing its commitment to supporting environmental and societal transitions. It is committed to making “impact accessible to all”⁽¹⁾ and to reinforcing its “global positive based on the strength of local solutions accessible to all.”⁽²⁾.

The Group’s strategy is accompanied by quantified objectives to implement and steer the Group’s concrete actions by 2026. All of these objectives (depending on the major service groups, customer categories, geographic areas and relations with interested parties) are set out in the table below.

1. Terminology for the strategic project VISION 2030 - Environmental impact, Groupe BPCE: https://www.groupebpce.com/en/csr/actor-in-the-environmental-transition/.
2. Terminology for the strategic project VISION 2030 - A Group with positive impact, Groupe BPCE: https://www.groupebpce.com/en/csr/our-csr-approach/.

A GROUP MOBILIZED TO DECARBONATE THE ECONOMY

IMPACT INSIDE

1. The scope for reporting this indicator is made up of the Banque Populaire and Caisse d’Epargne networks. This indicator sums the financing of energy renovation work for individual customers (natural persons). The calculation base for this indicator is made up of production data relating to energy renovation, ECO PTZ MPR and ECO PTZ.
2. The scope for reporting this indicator is made up of the Banque Populaire and Caisse d’Epargne networks. This indicator is the cumulative number of unique visitors who have consulted the “Sustainable Advisory and Solutions” section of the Banque Populaire and Caisse d’Epargne networks mobile app since 2023. The basis for calculating this indicator is made up of the almost real-time reporting of digital navigation data traced by the tool Adobe Analytics.
3. This indicator calculates, for Groupe BPCE, the percentage of corporate outstandings covered by an ESG dialog. The basis for calculating this indicator is made up of outstandings at risk covered by an ESG dialog for third-party corporate assets in the commercial sense.
4. This indicator sums the financing of the public sector, social housing and the social and solidarity economy. It is established for the Caisses d’Epargne on the basis of the Panorama BDR CE + HeR for social housing financing. Source FSE for the Banques Populaires.
5. It is established for the Caisses d’Epargne on the basis of the Panorama BDR CE + HeR for social housing financing. Source FSE for the Banques Populaires.
6. The scope for reporting this indicator is made up of the Banque Populaire and Caisse d’Epargne networks. This indicator lists the annual number of professional projects financed by microloans. The calculation basis for this indicator is made up of the number of pro take-off loans carried out in the Caisses and the amount of microloans made by the CE and BPs sent by external organizations (France Active, CREA-SOL and ADIE).
7. New system currently being rolled out.
8. 15% reduction achieved over the 2019-2024 period.

1.3.1.2 BUSINESS MODEL

* VISION 2030 strategic project terminology: https://www.groupebpce.com/le-groupe/plan-strategique/

1. 21.4% market share in outstanding loans, all non-financial sector customers (Banque de France Q3 2024).
2. Market share: 21.9% in household deposits/savings and 26.3% in home loans (Banque de France Q3 2024).
3. 2023 Kantar SME SMI survey.
4. Observatoire de la dette Finance Active des Collectivités Locales (published in 2024).
5. Insurance Argus 2023.
6. Cerulli Quantitative Update: Global Markets 2023 ranked Natixis Investment Managers the seventeenth largest asset management company in the world, based on the assets under management at December 31, 2022.
7. Population of adults under professional mandate estimated at more than 810,000 (source: Ministry of Justice) – Caisse d’Epargne network: nearly 350,000 protected customers, including over 325,000 adults at September 30, 2024.

1.3.1.2.1 Description of the main groups of products and/or services offered

As a universal, cooperative and regional bank, Groupe BPCE is a major player in Retail Banking and Insurance in France, in specialized businesses lines in Europe, and in Corporate & Investment Banking and Asset Management internationally.

Groupe BPCE’s business models and business lines are structured around two divisions: Retail Banking and the related business lines, mainly in France, and the global business lines of Groupe BPCE:

Retail Banking and Related Business Lines

• Retail Banking: Groupe BPCE is present in the Retail Banking field in France via its two cooperative networks, Banque Populaire and Caisse d’Epargne, along with Banque Palatine:
  • the Banques Populaires and Caisses d’Epargne provide their customers with a complete range of solutions in terms of account access, financing, savings, private management, insurance, payment and specialized financial services (such as leasing or factoring);
  • Banque Palatine provides its customers with a range of banking products (current accounts, real estate and personal loans, financial investments, financing solutions to meet environmental challenges).

• Insurance: BPCE Assurances is Groupe BPCE’s Insurance division. A fully-fledged insurer, it designs, distributes and manages a comprehensive range of personal and non-life insurance products for customers of Groupe BPCE’s banking networks:
  • personal insurance: life insurance, retirement savings, creditor insurance and individual and professional personal protection insurance;
  • non-life insurance: motor insurance, multi-risk home insurance, supplementary health insurance, personal accident insurance (GAV), multimedia equipment insurance, legal protection, parabanking insurance, professional car and multi-risk insurance, etc.

• Digital & Payments: the Digital & Payments division brings together all of Groupe BPCE’s business lines and expertise in the fields of innovation, digital, data and artificial intelligence, payments, and trade finance with Oney.

• Financial Solutions & Expertise: the Financial Solutions & Expertise division brings together the expertise in the financing business lines - these develop revolving credit and personal loan offers for the Group’s banks, offer a complete range of rental solutions (in particular equipment and real estate leasing, long-term leasing, and leasing with option to buy) and develop factoring solutions - as well as in the business lines of insurance, custodial and advisory services.

Global business lines

• Corporate & Investment Banking: Natixis Corporate & Investment Banking (CIB) provides advice and designs solutions for its corporate customers, financial institutions, institutional investors, financial sponsors and public sector entities, drawing on all of its expertise in advisory, investment and financing, commercial banking and capital markets. It is organized around five main business lines: Global Markets, Investment Banking, Real Assets, Global Trade, M&A.

• Asset & Wealth Management: Asset & Wealth Management develops solutions to meet the deposits and savings, investment, risk management and advisory needs of the various private banking and institutional customers of Groupe BPCE:
  • Asset Management: Natixis Investment Managers (Natixis IM) supports investors on all continents in building their portfolios by offering them a wide range of diversified and responsible solutions. Natixis IM offers a range of more than 200 strategies to enable its investor customers to achieve their investment objectives, and develops its offer around four key areas of expertise: fundamental active management, liability-driven management, real assets, and quantitative management;
  • Wealth Management: Natixis Wealth Management designs tailor-made wealth management and financial solutions to structure and manage the assets of business leaders, senior executives, large private investors and holders of family capital. Natixis Wealth Management supports its clients in their initiatives to undertake, invest and transmit by mobilizing a wide range of expertise: corporate advisory, origination, vanilla and complex financing, investment, wealth engineering, asset management and diversification solutions, in particular private equity;
  • Employee and retirement savings: Natixis Interépargne supports companies of all sizes in setting up and managing their employee savings and retirement savings (PEE, PERCO, Collective PER, Mandatory PER) as well as employee shareholding.

1.3.1.2.2 Description of major markets and/or customer groups

Groupe BPCE, a universal banking group, serves 35 million customers worldwide. The offers are aimed at a wide range of customers, including the main target customer groups:

• individual customers: Groupe BPCE is the second-largest bank for individuals⁽¹⁾ in France;
• professional customers: Groupe BPCE is the second-largest bank for professional customer and self-employed customers⁽²⁾. The professional market includes craftspeople, small retailers and liberal professions
• corporate customers: the Group supports companies of all sizes - SMEs, SMIs, medium-sized companies and large companies. Groupe BPCE, thanks in particular to its Banque Populaire network, is the No. 1 bank for SMEs⁽³⁾;
• local authorities: Groupe BPCE, in particular through the Caisse d’Epargne network, is the main private financier of local authorities⁽⁴⁾, the hospital sector⁽⁵⁾, and more generally the French public sector;
• social housing operators: Groupe BPCE is a long-standing partner and leading private banker in social housing⁽⁶⁾;
• Social and Solidarity Economy (SSE): Groupe BPCE, thanks to the action of its Banque Populaire and Caisse d’Epargne networks, is a major player in the private financing of the Social and Solidarity Economy. They support the various SSE structures, regardless of their size and status: cooperatives, mutuals, associations and foundations, employer structures in the historical sectors of SSE activity.

1.3.1.2.3 Description of the number of employees by geographical area

Groupe BPCE has over 100,000 employees, nearly 90% of whom are based in France.

1.3.1.2.4 Description of products and services prohibited in certain markets

ESG sector policies govern Groupe BPCE’s activities in sectors deemed sensitive from an environmental, social and governance (ESG) point of view.

Concerning Groupe BPCE’s banking activities

• Thermal coal: in October 2015, Natixis Corporate & Investment Banking (CIB) committed to no longer finance coal-fired power plants and thermal coal mines worldwide. This policy has gradually been strengthened. In 2021, Groupe BPCE extended its policy to all of its banking activities and committed to a strategy aimed at gradually reducing its banking activities’ exposure to thermal coal to zero by 2030 (for European Union and OECD countries) and 2040 (for the rest of the world).
• Oil and gas industry: published for the first time in 2017, this ESG policy, initially applicable to Natixis CIB’s activities, was extended in 2023 to all of Groupe BPCE’s banking activities and was strengthened with new criteria.

Concerning Natixis CIB’s banking activities

• Defense industry: Natixis CIB excludes the financing, investment and provision of services to companies involved in the production, storage and trade of anti-personnel mines and cluster munitions.
• Tobacco industry: Natixis CIB has undertaken to cease all dedicated financing related to tobacco activities, as well as all non-dedicated financing in favor of a company whose business is 25% or more tobacco-based.

The European asset management companies affiliated with Natixis Investment Managers also apply sector and/or exclusion policies:

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

1. Market share: 21.9% in household deposits/savings and 26.3% in home loans (Banque de France Q3 2024).
2. 37% (rank 2) penetration rate among professional customers and self-employed customers (Pépites CSA 2023-2024 survey).
3. 2023 Kantar SME SMI survey.
4. Observatoire de la dette Finance Active des Collectivités Locales (published in 2024).
5. Observatoire Finance Active Établissements de Santé (published in 2024).
6. Repères 136 USH of August 2024 (Les HLM en chiffres).

BPCE Assurances has implemented the following sector policies as part of its investments:

• Tobacco sector: total exclusion of producers and exclusion of distributors whose tobacco-related turnover exceeds 5% of their total business.
• Controversial weapons: total exclusion.
• Thermal coal: for new investments, exclusion of producers whose turnover from thermal coal is higher than 10%, the annual coal production exceeds 10 million metric tons, or the electricity capacity generated from coal is greater than 5 GW. Distributors developing new thermal coal generation capacities of more than 300 MW are also excluded. For existing investments, divestment planned for 2030 at the latest for companies in OECD countries and for 2040 for companies in non-OECD countries.
• Oil & Gas: for new investments, companies developing new upstream fossil fuel (conventional or non-conventional) exploration or production projects, as well as those whose production of unconventional hydrocarbons or those with a high environmental impact exceeds 10% of their total activity are excluded. For existing investments, divestment no later than 2030 for companies that do not meet these criteria.
• International guidelines: for new investments, companies that violate the United Nations Global Compact (UNGC) and the OECD guidelines are excluded. For existing investments, priority divestment of companies that violate international principles.
• Pesticides: companies whose turnover from the production or marketing of pesticides exceeds 5% and which do not have a biodiversity strategy whose targets are aligned with target 7 of the Kunming-Montreal agreements for new investments are excluded. For existing investments, divestment set no later than 2030 for companies that do not meet the defined criteria.

1.3.1.3 LABELS AND COMMITMENTS

Public commitments that meet demanding international standards

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

Global Compact

Since 2003, the Group has been a participating member of the Global Compact (United Nations Global Compact), which defines ten principles relating to respect for human rights, labor standards, environmental protection and the fight against corruption.

Principles for Responsible Investment (PRI)

Since 2008, through Natixis, the Group has adhered to the PRI, which supports institutional investors in incorporating environmental, social and corporate governance considerations into the investment decision-making process.

Equator Principles

Since 2010, through Natixis, the Group has been a signatory of the Equator Principles. They aim to take into account social and environmental risks in the context of project financing.

Principles for responsible banking, UNEP Finance Initiative

Groupe BPCE and Natixis have signed the Principles for Responsible Banking and are committed to strategically aligning their activities with the United Nations Sustainable Development Goals (SDGs) and the Paris Climate Agreement.

Net Zero Banking Alliance

In July 2021, Groupe BPCE joined the Net Zero Banking Alliance (NZBA), a financial initiative of the United Nations Environment Program (UNEP FI) covering more than 40% of the assets financed by banks worldwide. This alliance between banking institutions is a decisive step in the mobilization of the financial sector.

In accordance with its commitment to align the trajectory of its portfolios with the objective of carbon neutrality by 2050, Groupe BPCE has published its ambitions for the eleven sectors with the highest carbon emissions (power generation, oil and gas, automotive, steel, cement, aluminum, aviation, commercial real estate, residential real estate and agriculture).

Net Zero Asset Owner Alliance

Since 2022, BPCE Assurances has been a member of the Net Zero Asset Owner Alliance (NZAOA), an international group of investors committed to transitioning their investment portfolios with the aim of contributing to carbon neutrality by 2050.

act4nature

By joining act4nature international in 2024, Groupe BPCE is strengthening its commitment to the environment by renewing the partnership supported by Natixis since 2018.

By joining act4nature international, a coalition that mobilizes companies, public authorities, scientists and environmental associations in favor of the protection, enhancement and restoration of biodiversity, the Group has set itself 24 proactive objectives as part of its banking, insurance and investing activities.

1. Certain affiliates of Natixis Investment Managers (Natixis IM) scope, BPCE Assurances joining the PRI in 2016.
2. Commitment made by Natixis in 2018, extended to include Groupe BPCE in 2024.

Banque Populaire network and Caisse d’Epargne network labels

Actions carried out by Groupe BPCE are often assessed by public and private bodies who provide certificates that guarantee compliance with a particular standard or label.

1.3.1.4 VALUE CHAIN

As a financial institution, Groupe BPCE receives funds in the form of customer deposits or purchases of financial instruments by investors and grants loans to its customers (banking transformation function).

The downstream value chain includes customers who benefit from Groupe BPCE’s products or services, particularly loans.

The upstream value chain includes suppliers of products or services.

Own operations concern resources (e.g. employees, IT, premises, etc.).

1.3.2   SBM-2 - Interests and views of stakeholders

Taking into account stakeholder expectations is an essential exercise to better identify and assess the Group’s sustainability impacts. Groupe BPCE’s stakeholder consultation process is based on a large number of systems that aims to involve its stakeholders in its process of identifying and assessing impacts, risks and opportunities, as well as levers for improving both environmental and societal topics. These systems are detailed in the table below.

The Group’s cooperative model places dialog with stakeholders at the heart of its actions. The local presence of the Banques Populaires and the Caisses d’Epargne enables the Group to be attentive to everyone and understand society’s expectations, by promoting local ecosystems and dialog with its stakeholders such as chambers of commerce, professional associations, players in the social and solidarity economy (SSE), entrepreneurial ecosystems, educational structures, associations, foundations, mutuals that the Group has historically supported, given its role as a major financier of the social and solidarity economy.

By holding the company’s capital through cooperative shares, customers become cooperative shareholders and actively participate in the life, strategic and sustainable development of their bank. The members of the Board represent the cooperative shareholders, the regions and civil society within the governance of their bank.

Everywhere in the territories in France and in the regions of the world where the Group operates, stakeholder expectations are identified and taken into account through regular relations with the executives of the Group’s companies, the Fédération Nationale des Banques Populaires, the Fédération Nationale des Caisses d’Epargne, the employee representative bodies, investors roadshows, meetings with rating agencies and NGOs (non-governmental organizations). Lastly, discussions with regulators, and image or forward-looking surveys are all sources of identification of changes in stakeholder expectations.

Summary of stakeholder dialog

1. Net promoter score

Certain stakeholders were consulted as part of the double materiality assessment (see 1.5.1.1 IRO-1).

1.4.1   GOV-1 - The role of the administrative, management and supervisory bodies

1.4.1.1   COMPOSITION AND DIVERSITY OF GROUPE BPCE’S MANAGEMENT AND SUPERVISORY BODIES

Supervisory Board and Management Board

The Supervisory Board of Groupe BPCE has 19 members⁽¹⁾: 7 representatives of the Banques Populaires, 7 representatives of the Caisses d’Epargne, 3 independent members⁽²⁾ and 2 employee representatives. The Supervisory Board includes 6 non-voting directors acting in an advisory capacity.

As of 31st December 2024, with eight women on its Supervisory Board out of a total of seventeen members, Groupe BPCE had a proportion of women of:

• 47.05%⁽³⁾ (in accordance with Article L. 225-79 of the French Commercial Code, members representing employees are not taken into account in this calculation);
• 42.11%, in accordance with ESRS 2 (European Sustainability Reporting Standards 2) of the CSRD (Corporate Sustainability Reporting Directive).

The Management Board of Groupe BPCE is composed of four members⁽⁴⁾, including a Chairman. The diversity rate is 50%⁽⁵⁾.

The modalities and details of the composition of the Supervisory Board and Management Board (as well as the Executive Management Committee) are provided in Chapter 4.

Thus, the members of the Supervisory Board and the Management Board are appointed in accordance with the appointment and succession policy (adopted by the Supervisory Board at its meeting of February 7, 2024), which specifies the diversity policy applicable to them.

The Appointments Committee - responsible for formulating proposals concerning the choice of Board members, non-voting directors and external independent members (in compliance with legal and statutory rules and in accordance with the Supervisory Board’s internal rules) - thus verifies the suitability of candidates to join the Board in view of their good repute, skills and independence while pursuing an objective of diversity within the Board, i.e. a situation where the characteristics of the members of the Board differ to a degree ensuring a variety of views within the Board. The Group’s cooperative nature contributes to this diversity.

The committee strives to observe the following diversity criteria:

• training,
• balanced geographical representation,
• representation of the different types of market.

When assessing a candidate for the Supervisory Board, the Appointments Committee strives to maintain or achieve a balance and have a skill set appropriate for the Group’s activities and strategic project, as well as the technical responsibilities assigned to the various Supervisory Board committees.

Sustainability expertise and skills of the Supervisory Board

Skills are assessed collectively within the Supervisory Board, which favors their complementarity.

The Supervisory Board is mainly composed of representatives from the Banques Populaires and the Caisses d’Epargne, and in particular of the directors and Chairmen of the Boards from both networks. The board chairmen are first and foremost cooperative shareholders of their bank and have in-depth knowledge of the cooperative model, the region and regional specificities.

The skills of the members are reported in the collective skills matrix of the Supervisory Board in Chapter 4⁽⁶⁾. This matrix notably mentions all the regulatory skills expected by the supervisor (including banking skills such as: banking and financial markets, accounting and auditing, interpretation of a credit institution’s financial information, risk management, etc.). In addition, these elements are supplemented by the information appearing in the terms of office sheet of each member⁽⁷⁾, which describes his or her experience in detail.

In view of the Supervisory Board’s collective skills matrix, the Supervisory Board’s average skill level, particularly with regard to ESG skills, is as follows:

• Knowledge and experience of climate and environmental risks: 3.55 / 5

This expertise covers the understanding of climate and environmental risk and its challenges for a banking group, the general regulatory context as regards the environment, the specific expectations on the banking sector, and the measurement of this risk and its main indicators. It also covers knowledge of the action plans implemented by the Group.

1. The Supervisory Board of BPCE exercises permanent control over the management carried out by the Management Board and must include, according to the Group’s articles of association, between 10 and 19 members (non-executive company directors) as well as 6 non-voting directors chosen in accordance with the procedures provided for in the diversity policy adopted on February 7, 2024.
2. i.e. a proportion of 15.79% of independent members on BPCE’s Supervisory Board. The proportion of independent members on the board committees is specified in Chapter 4.
3. The Supervisory Board aims for a minimum of 40% representation of the under-represented gender, a ratio calculated by the ratio of the number of women members of the Supervisory Board to the total number of Supervisory Board members, it being specified that the members representing the employees are not included in the calculation.
4. The Management Board has the broadest powers and must include between two and five members according to Groupe BPCE’s articles of association (executive company directors).
5. The Management Board of BPCE, which is not subject to any regulatory or statutory obligations, calculates this ratio by dividing the number of women members of the Management Board with the total number of members of the Management Board.
6. The matrix presents the average of the collective skills of all of the members. It is based on skill levels (between 1 and 5) as declared by the members. During the assessments, the Appointments Committee checks the consistency of the declared skill levels with the CVs and training completed.
7. See 4.3.5 “Directorships and offices held by corporate officers”.

• Social and solidarity economy: 4.47/5

This expertise covers the understanding of the various areas of intervention of the social and solidarity economy (fair trade, responsible consumption, short supply chains, solidarity-based finance, integration through economic activity, confiscation of criminal assets for the use of social utility, social currencies and non-monetary exchange systems, etc.) and its specific challenges, knowledge of social innovations, the role of the various players, and interactions with public authorities.

• Cooperative banking experience: 4.47 / 5

This expertise covers the specificities of the Banque Populaire and Caisse d’Epargne networks, banks and cooperative companies, which are owned by their cooperative shareholders. As cooperative banking institutions, the operations and missions of the Banques Populaires and the Caisses d’Epargne are governed by law (as is BPCE as the central institution of these institutions): participatory governance, regional proximity, legal duties to implement the principles of solidarity and fight against exclusion, promotion and collection of savings, development of provident insurance, contribution to the protection of popular savings, financing of social housing, improvement of local and regional economic development, and fight against banking and financial exclusion of all players in economic, social and environmental life. Knowledge of these specificities, the very essence of the Group’s model, is the basis of this “cooperative banking experience”.

• Regional specificities: 4.21 / 5

This competence involves understanding and taking into account the economic and social strengths and weaknesses of the territories.

• Economic and regional environment: 4.34 / 5

This expertise covers knowledge of the strategies for the development, revitalization and optimization of a region as well as understanding of the role of the various players and partners and the legal and financial constraints.

Training program

In order to strengthen the skills available to the Supervisory Board, training provided by internal and/or external providers is offered to Board members, particularly on sustainability issues. The training program takes into account the diversity of experiences and the needs of the Board members, as well as the proposals made as part of the Board’s annual assessment.

Details of the training program offered to Supervisory Board members are provided in Chapter 4.

The training offered in 2024 in terms of sustainability, both as part of the regulatory initial training and continuing training, were as follows:

• climate and environmental risks: training delivered by internal and external providers with the aim of understanding climate risk, the general regulatory context regarding the environment, and the specific expectations on the banking sector;
• the challenges of the energy transition and the management of climate and environmental risks: internal training with the aims of improving knowledge about the integration of ESG criteria in risk monitoring, presenting the main regulatory requirements related to climate and environmental risks, and describing the action plans implemented by the Group to respond to them;
• CSRD and transition plan: training delivered by internal and external providers, with the aim of ensuring a good understanding of the CSRD regulatory requirements and the challenges related to this new regulation for Groupe BPCE;
• the climate solutions fresco: external training with the aim of achieving good understanding of the impacts and challenges related to climate risks on the various sectors of the economy;
• Retail Banking operating model: internal training aimed at seeing how the Group is accelerating its transformation of the support functions and how future technologies can trigger new dynamics in Retail Banking operating models;
• governance of cooperative ‘banks’, overview of the governance and organization of cooperative banks in France and Europe: training delivered by internal and external providers with the aim of presenting an overview of the governance and organization of cooperative banks in France and Europe.

1.4.2 GOV-2- Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies

1.4.2.1 SUSTAINABILITY TOPICS ADDRESSED BY THE ADMINISTRATIVE, MANAGEMENT AND SUPERVISORY BODIES

Organization of governance relating to Groupe BPCE’s sustainability issues

The Supervisory Board supervises and puts the Group’s ESG strategy into perspective. The Executive Management Committee of Groupe BPCE validates the ESG strategy, ensures its implementation and oversees the Group’s risk management (the composition and diversity of the management and supervisory bodies, the roles and responsibilities of the bodies are detailed in Chapter 4 of the Universal Registration Document - Report on corporate governance).

Banques Populaires and Caisses d’Epargne place ESG at the heart of their business model, and ESG issues have historically been an integral part of the governance of each institution.

At the level of the Supervisory Board and its committees

The Supervisory Board meets as often as the company’s interests and legal and regulatory provisions require. The frequency is at least once per quarter. Several specialized committees have been set up by the Supervisory Board and carry out their activities under its responsibility. Their duties are defined in the Supervisory Board’s internal rules. The Chairman of each of these committees reports on the committee’s work to the Supervisory Board.

In addition to the subjects regularly addressed during Board meetings, such as the quarterly reports of the Management Board, related-party agreements, executive approvals, current events and other matters for information, sustainability subjects are also examined mainly in the context of committee minutes.

At the Executive Management level

The double materiality assessment was presented to the Cooperative and CSR Committee in November 2024 and to the Audit and Investment Committee in December 2024. These two committees communicated their report at the Supervisory Board meeting held in December 2024.

The material impacts, risks and opportunities focus on climate change, value chain workers, affected communities, consumers and end-users and business conduct. The skills of the members of the management and supervisory bodies in connection with these IROs are available in Chapter 4⁽¹⁾.

These diverse topics are the responsibility of various specialized committees and the material matters are dealt with within the ordinary framework of the existing bodies. For example, the material matters related to the climate are dealt with by the Environmental Transition Strategy Committee (CTSE), which is notably tasked with defining the Group’s Impact strategy as regards the environmental transition and overseeing its implementation, through action plans, business line indicators and measurement of ambitions. It is in this body that the decarbonization action plans and/or trajectories of the eleven highest-emitting sectors published by Groupe BPCE were validated, before being presented to the Executive Management Committee (CDG).

An “Impact Inside” approach managed by the Sustainability Office

The Sustainability Office which reports directly to the Chairman of the Management Board, proposes, validates and implements the Group’s ESG strategy. It plays a cross-functional role within the Group, carrying out the following key missions:

• co-construct the VISION 2030 of the Group’s Impact on the Environmental, Social and Governance (ESG) dimensions;
• develop and deploy ESG expertise and ensure the Group’s representation and communication;
• conduct and interpret scientific and competitive monitoring and support regulatory monitoring, to ensure continuous improvement;
• manage the Impact 2026 program and carry out structuring projects within its scope in accordance with Group standards and regulatory expectations;
• ensure overall coordination and support each sector’s “Impact Inside” operations while implementing the necessary synergies.

The “Impact Inside” approach is being rolled out:

• with the Executive Management Committee, which oversees projects related to the implementation of the Impact VISION 2030 for the Group, with a regular review of the portfolio of structuring projects;
• with the Strategic Environmental Transition Committee, which validates the main operational guidelines and monitors the deployment of environmental projects;
• via the institutions, with an Impact Committee, composed of CEOs of Banques Populaires and Chairmen of Caisses d’Epargne, which guides the Impact program and monitors the progress of projects, with the various functions of the divisions notably with the Impact/CSR function to ensure a global vision of the program, a co-construction dynamic and its implementation in the institution;
• with the Group’s business lines through specific systems adapted to each business line (the global business lines of Groupe BPCE, Insurance, FSE and D&P), based on existing committees, notably including work between business line departments and a dedicated coordination to co-construct and implement the Group Impact program with the ESG managers.

1. Matrix of the collective skills of the Supervisory Board and terms of office sheets of the members.

1.4.3 GOV-3 - Integration of sustainability-related performance in incentive schemes

Concerning the members of the Supervisory Board of BPCE SA

With the exception of the Chairman, who receives a fixed annual fee, the members of the Supervisory Board receive remuneration on the basis of their activities. The Chairman and Vice-Chairman of the Supervisory Board do not receive any additional remuneration for their participation in committees.

Each remuneration payment relates to the corporate officer’s attendance at Board Meetings and is calculated according to the total compensation package set by by each company’s General Meeting.

Concerning the members of the Management Board of BPCE SA

For the 2024 fiscal year, CSR and employee cooperative shareholding within BPCE are one of the five qualitative criteria influencing the variable pay of Management Board members. The variable portion of pay relating to the five qualitative criteria represents 40% of the total variable pay, with no specific weighting for each of the individual criteria. The achievement rate was assessed overall by taking into account the attention paid to the five criteria, taken as a whole, including CSR topics and employee cooperative shareholding within BPCE.

On February 6, 2025, on the proposal of the Remuneration Committee, BPCE’s Supervisory Board decided to set the Management Board’s variable pay targets for the 2025 fiscal year by incorporating a specific criterion related to the environment, climate and decarbonization trajectories with a weighting of 5%.

1.4.4 GOV-5 - Risk management and internal controls over sustainability reporting

MAIN FEATURES OF THE RISK MANAGEMENT AND INTERNAL CONTROL SYSTEM LINKED TO THE SUSTAINABILITY REPORTING PROCEDURE

1.4.4.1 PREPARATION AND PUBLICATION OF SUSTAINABILITY INFORMATION

Roles and responsibilities

Within the Group, the preparation and processing of sustainability information is mainly the responsibility of the Group Finance division which mobilizes its Architecture & Reporting (A&R) and Financial and Non-Financial Communication teams and the Sustainability Office.

FINANCE DIVISION

Architecture and Reporting

Reporting to the Finance division, the Architecture and Reporting (A&R) department is responsible for securing the key Information Systems Finance & Risks applications, ensuring the reliability of complex production processes (data transformed with the preparation of regulatory and management reports) and ensuring that these processes comply with BCBS 239 principles⁽¹⁾.

In 2024, the department created a unit dedicated to managing non-financial issues closely related to the management of the financial statements. The Responsible Finance Management (RFM) structure is in line with the new “Impact Inside” model.

The new RFM department played a key role in coordinating the work to draw up Groupe BPCE’s sustainability report:

• coordination of project committee and governance internally, including interaction with other Group entities that prepare their own sustainability report;
• strengthened coordination of the data strategy and the processes for producing the regulatory indicators required by the ESRS, including the conduct of a test system involving all production entities;
• active monitoring of best practices in force in the market (methodologies for producing indicators, transition plan);
• acculturation of the Finance function of the Group’s companies on the new CSRD challenges, in particular via the existing National Finance Committee (NFC) bodies;
• interaction with the College of Auditors.

Financial and non-financial communication

Teams are involved in the CSRD set-up and responsible for the production of the Universal Registration Document. They drive the narrative production process. The drafting of the narratives is entrusted to the production business lines, who are experts in the themes. The project teams perform the following functions:

• identify, integrate and raise awareness among the ESRS-themed narrative writers of the new CSRD challenges as well as the editorial requirements required by the standard;
• provide tools to the production business lines such as an editorial guide, methods for monitoring production and completeness, and instructions for proofreading and validation with the managers of the contributing divisions;
• manage the narrative collection process with the Sustainability Office and data collection in collaboration with the Architecture & Reporting department;
• ensure the production of the sustainability report within the milestones of the URD production schedule;
• organize the mechanisms necessary to collect investors’ expectations.

This approach aims to ensure a good understanding of the spirit of the EFRAG standard and guide(2). The drafting work is carried out according to a schedule and in the collaborative tool used to draft the URD.

1. The Basel Committee on Banking Supervision.
2. European Financial Reporting Advisory Group.

SUSTAINABILITY OFFICE

The Sustainability Office, which reports directly to the Chairman of the Management Board, proposes, validates and implements the Group’s ESG strategy. It plays a cross-functional role within the Group and, as part of the CSRD project and is more specifically involved in the following projects:

• CSRD acculturation: the Sustainability Office has designed and runs acculturation sessions for employees, various business lines (Purchasing, Governance, Compliance, etc.) and the Group’s management bodies, subsidiaries and institutions. The educational objective of these sessions is to put into perspective the challenges of the CSRD and the sustainability report, explain the regulatory requirements and new structuring concepts, present the organization of the project at Group level and the expected contributions;
• double materiality assessment: this analysis was carried out in two stages (for a detailed description, see ESRS 2 IRO-1):
  • the identification of impacts, risks and opportunities (IRO) relevant to Groupe BPCE’s activity was coordinated by the Finance division (A&R) and the Sustainability Office, with the operational support of the Retail Banking & Insurance business lines, the global business lines of Groupe BPCE, as well as the ESG Risk, Operational Risk, Achats & Services, Human Resources, Compliance, Technology and Operations, and Public Affairs departments at group level. The double materiality assessment was carried out in two phases, A and B, by the Finance department and the Sustainability Office respectively. Phase A lead to identify the topics and subtopics of the ESRS relevant to Groupe BPCE, through workshops with internal business line experts, and then to carry out an initial identification of the IROs. Phase B lead to draw up the final list of relevant IROs for Groupe BPCE, as well as to rate them,
  • assessment of the materiality of the IROs: the Sustainability Office is responsible for establishing, on behalf of the Group, the IRO rating methodology and it coordinates and supervises the rating of IROs, in conjunction with the internal stakeholders mentioned above; the business lines and functional departments are responsible for rating the IROs falling within their scope;
• communication strategy and editorial content: the Sustainability Office ensures that the editorial content of the sustainability report is relevant and consistent with the Group’s strategy on sustainability issues, for which it is responsible;
• transition plan: the Sustainability Office is responsible for drafting the transition plan;
• coordination of the Banques Populaires and Caisses d’Epargne: the Sustainability Office supports the institutions and defines a framework, guidelines and certain content for the preparation of their Impact reports (non-regulatory report produced by certain institutions).

Methods for producing and publishing sustainability reports

In accordance with the requirements defined by the Corporate Sustainability Reporting Directive (CSRD), the central institution prepares the sustainability report.

It also ensures the proper application by the entities subject to this requirement of the rules defined by the Group and verifies compliance with these requirements. Within the Group, the entities subject to the requirement to publish a sustainability report are Natixis, BPCE Assurances, BRED Banque Populaire and Banque Palatine.

To ensure the reliability of the production process, the central institution uses:

• a project structure dedicated to the publication of sustainability reports and distributed to all Group entities;
• a process for consolidating all the information to be published in the sustainability report, including controls to ensure the consistency of the information published and the analyses;
• a complete body of documentation;
• a harmonized permanent control system, the organization of which is described in the following Section (GOV-5 1.4.4.2).

1.4.4.2 GENERAL ORGANIZATION OF PERMANENT CONTROL

General system

The internal control system defined by the Group contributes to the control of risks of all kinds and is governed by an umbrella charter  –  the Group Internal Control Charter  –  which stipulates that this system is designed, in particular, to ensure “[…] the reliability of financial and non-financial information reported both inside and outside the Group.”

The Group has defined and implemented a permanent control system to ensure the quality of this information, in accordance with the requirements defined by the Ministerial Order of November 3, 2014 on internal control, or any other regulatory obligations relating to the quality of reports, and in particular for the publication of information on sustainability.

For the sustainability report, the internal control system must ensure compliance with the requirements defined by:

• the Corporate Sustainability Reporting Directive (CSRD);
• the Group, in the framework for the preparation and publication of reports and management indicators, which aims to harmonize the reporting practices within the Group.

To ensure strict independence in the implementation of controls, the permanent control system is based annually on two levels of controls with:

• a first level exercised by all those involved in the production and reporting process. The following functions produced the information used for the sustainability report: Finance, Risk, Human Resources, Impact/CSR, Purchasing, Corporate Secretary’s Office and Governance;
• a second level is handled by independent units within the Risk, Compliance or Permanent Control functions. For the CSRD reporting, this work is coordinated by the Group Financial Control (Group Corporate Secretary’s Office) in conjunction with the other level two control players (risk).

Level one controls

The level one controls consist of self-checking and control procedures implemented by each unit or entity responsible for producing sustainability information.

They aim in particular to ensure compliance with the rules defined by the CSRD and by the Group in the framework for the preparation and publication of reports and management indicators.

The level one controls are carried out throughout the report production process. The definition and implementation of these controls is the responsibility of each function or entity in charge of production, throughout the chain of contributors to the CSRD sustainability report. The production processes have been documented internally.

The results of the controls are formalized by the units or entities responsible for producing the information relating to sustainability and they specify, where applicable, any anomalies identified and their remediation plans to resolve them over the long term.

With regard to the indicators, the level one controls relate in particular to:

• reconciliation with the financial statements, if applicable;
• analysis of changes;
• the quality of the data collected from external suppliers, where applicable;
• drafting of a documentary corpus describing the planned production process and first-level controls.

The level one controls are carried out either in the technical production chains or by the business lines, with particular attention paid to processes involving office automation and manual interventions.

In addition, and in accordance with the requirements of the CSRD regulations (MDR-M(1)), the methods and main assumptions underlying the indicators, as well as the associated limitations, have been documented internally and reproduced in the CSRD report to provide the reader with all the background information necessary to understand the published indicators. As this is the first year of application of the system related to the assessment of double materiality, the internal control process is under construction and will be strengthened in the coming years.

Level two controls: independent review of the sustainability report

GENERAL SYSTEM

To ensure that the main reports published within the Group comply with all the requirements defined by the Group or by regulations, the Group has defined a method for assessing reports called the independent review of reports based on the implementation of strict criteria and carried out by independent functions.

This review, organized to ensure that the regulatory requirements are met, mainly aims to obtain an opinion or reasonable assurance that the reports are produced and published in a satisfactory internal control environment and that they include reliable and clear data that is useful and auditable.

Coordinated by the Group’s Corporate Secretary’s Office (Group Financial Control), this system is mainly carried out in four major phases:

1. a risk assessment phase aiming to identify the indicators to be checked, to plan the controls and to include the system in an annual control plan N+1 (under PRISCOP(2)) validated by the Internal Control Coordination Committee. The risk assessment is carried out on all the indicators provided for in the publication of the sustainability report, based on the double materiality assessment, to identify gross risks, and on the internal procedures to assess the risk management system related to these indicators. The results of the assessment are based on three levels of risk (low, moderate and high) in order to select those that require a targeted review;
2. an implementation phase of the level two controls carried out, according to the scoring method, via a grid of rated controls, in accordance with the rules set out in the permanent control framework document on a scale ranging from 1 (requirement not met) to 4 (requirement fully met):

These controls are based on six areas of analysis, weighted from 1 to 3 and relating to:

• the quality of the documentation;
• the robustness of the organization relating to the production and publication of the report;
• the quality of the audit trail of the data and/or indicators included in the reporting;
• the effectiveness of the system of level one controls;
• the accuracy of the data and/or indicators published and their consistency with the information provided in other publications;
• the clarity of the information.

1. Minimum Disclosure Requirement - Metrics.
2. Group permanent control tool.

3. a control review phase: the results of the controls are formalized and presented in a summary note, which presents the work carried out and the conclusions, specifying in particular the anomalies identified and, where applicable, the recommendations made (or action plans or corrective measures). The results are included, by criterion, in the Group’s permanent control tool (PRISCOP) and the conclusions are shared with the audited units, the external auditors (Statutory Auditors in particular) and with the supervisory body or its specialized bodies (the Audit and Investment Committee on the one hand, and the Cooperative and CSR Committee on the other hand);
4. a phase of monitoring corrective actions (recommendations issued) and/or areas for improvement identified: this monitoring is carried out in conjunction with the business lines and after the publication of the Group’s sustainability report in order to strengthen the system for subsequent publications. Their implementation will also be monitored for the actions reported under PRISCOP by the Group entities subject to the publication of this report.

MAIN FEATURES OF THE ENVIRONMENTAL, SOCIAL AND GOVERNANCE RISK MANAGEMENT SYSTEM

The environmental, social and governance risk management system is described in detail in Chapter 7, section 16 of the Universal Registration Document.

Definition of ESG risks

ENVIRONMENTAL RISKS

The environmental risks fall into two main risk categories:

• physical risks arising from the impacts of extreme or chronic climate or environmental events (biodiversity, pollution, water, natural resources) related to the activities of Groupe BPCE or its counterparties;
• transition risks, arising from the impacts of the transition to a low-carbon economy, or to one with a lower environmental impact, regarding Groupe BPCE or its counterparties, including regulatory changes, technological developments, and the behavior of stakeholders (including consumers).

SOCIAL RISKS

Social risks arise from the impacts of social factors on Groupe BPCE’s counterparties, including issues related to the rights, well-being and interests of individuals and stakeholders (the company’s workforce, workers in the value chain, communities concerned, consumers and end-users).

GOVERNANCE RISKS

Governance risks arise from the impacts of governance factors on Groupe BPCE’s counterparties, including in particular issues related to ethics and corporate culture (governance structure, business integrity and transparency, etc.), supplier relationship management, influence activities and business practices.

ESG risk management framework deployment program

The ESG Risk department coordinates the implementation of the ESG risk management system at Groupe BPCE level through a dedicated program. This program, initiated in 2021, was reviewed and strengthened during 2024 in line with Groupe BPCE’s climate and environmental commitments within the framework of the VISION 2030 strategic project and the regulatory requirements. It defines a multi-year action plan aligned with the action plan that implements the 2024-2026 strategic project. It is directly linked to the strategy and actions implemented by the Impact program. This program is monitored quarterly by the ESG Risk Committee, Groupe BPCE’s Supervisory Board and the European supervisor.

This program is structured around the following four topics:

• ESG risk governance: committee procedures, roles and responsibilities, remuneration;
• strengthening risk knowledge: monitoring systems, sector analyses and assessments, risk reference framework, risk analysis methodologies and processes, data;
• operational integration of work: in coordination with the other functions of the Risk division, consideration of ESG risk factors in their respective management systems and decision-making processes;
• consolidated risk management mechanisms: dashboards, contributions to RAF / ICAAP / ILAAP, training and acculturation plan for directors, managers and employees, contribution to non-financial communication.

The execution of this program mobilizes the main internal stakeholders in terms of ESG risks, in particular the Sustainability Office, the teams and functions of the other departments of the Risk division, the Finance division and the Compliance department, as well as Groupe BPCE business lines, in particular the departments in charge of developing sustainable finance activities.

Integration of ESG risks into the risk management framework

Based on specific ESG risk assessment methodologies, Groupe BPCE is gradually integrating ESG risk factors into its operational decisions through the existing systems in the bank’s main risk functions.

The process of identifying and assessing climate risks and the associated action plans are described in Chapter E1 - Climate change (in Sections 2.2.2.1 and 2.2.3.4 respectively).

Reputational and/or litigation and liability risks have been identified as material in the chapters Climate change, Workers in the value chain, Affected communities and Consumers and end-users, and are covered by the following sections:

REPUTATIONAL RISK

The growing awareness and sensitivity of citizens and economic players to environmental, social and governance issues is leading to increased exposure to reputational risks related to these topics.

Faced with these risks, Groupe BPCE relies on a reputational risk management system overseen by Groupe BPCE Risk division and structured around the Group Reputation Risk Committee, which is tasked with reviewing the most sensitive issues at Groupe BPCE level.

This system is based on the measures implemented in the decision-making processes in order to assess reputational risks and implement mitigation measures if necessary. This concerns in particular:

• the responsible purchasing policy, which requires knowledge and assessment of suppliers’ ESG risks, and the implementation of a carbon clause in supplier contracts since 2024;
• the new products/new activities (NPNA) system concerning the characteristics and communication related to Groupe BPCE’s products and activities, which includes a systematic opinion from the ESG Risk department and the Impact department;
• the application of sector CSR policies as part of the new relationship, credit and investment processes.

Given the particular sensitivity of its activities to reputational risks, a dedicated system is deployed by Natixis. This system is based in particular on an assessment of the reputational risk arising from Natixis CIB’s customers, from inception and throughout the business relationship, including the management of controversies. It is carried out in the normal course of business and, to the extent possible, using the various existing governance mechanisms and committees. A reporting process also makes it possible to report all the files likely to generate a significant risk of damage to the reputation of Natixis and/or Groupe BPCE, composed of members of the entity’s Executive Management.

In addition, a system for monitoring the Group’s ESG reputation has been set up, conducting monthly monitoring of the main controversies related to ESG issues that have involved Groupe BPCE and their impact on its overall reputation score. This monitoring is presented quarterly to the ESG Risk Committee.

Groupe BPCE plans to continue to enhance these systems in the course of 2025, in particular by defining a framework for monitoring voluntary commitments and strengthening its reputational risk management system.

LITIGATION RISKS

The environmental, social and governance issues are likely to lead to litigation risks for Groupe BPCE. These can be based on legal foundations specific to the ESG issues (Duty of Care, international treaties or European legislation on the climate and the environment), on broader principles applied in this context (competition law, consumer law, criminal law), or unilateral commitments made by Groupe BPCE.

Groupe BPCE has identified and integrated into its operational risk mapping three main litigation and liability risk situations specifically related to ESG issues:

• communication using the ecological/sustainable argument in a misleading manner (greenwashing);
• non-compliance with the voluntary commitments made by Groupe BPCE or voluntary commitments deemed insufficient;
• controversial activities of Groupe BPCE or its entities, customers and/or suppliers.

As for the reputational risks, the risk management relating to these three situations is based on a set of measures integrated into the Group’s main decision-making processes.

In addition, Groupe BPCE’s Legal department also defines and disseminates best practices in terms of communication on climate and environmental issues and supports Groupe BPCE’s business lines and functions in their implementation regarding internal and external communication.

1.4.5   GOV-4 - Statement on due diligence

The table below maps the information concerning the due diligence procedure included in Groupe BPCE’s sustainability report.

1.5.1   Disclosures on the materiality assessment process

1.5.1.1    IRO-1 - DESCRIPTION OF THE IDENTIFICATION AND ASSESSMENT OF MATERIAL IMPACTS, RISKS AND OPPORTUNITIES PROCESS

1.5.1.1.1   Double materiality definition

The double materiality exercise is the starting point for the preparation of the sustainability report.

Double materiality has two dimensions: i) materiality from an impact point of view and ii) materiality from a financial point of view.

The impacts, risks and opportunities which are identified as material represent the material matters on which the content of the sustainability report is based.

1.5.1.1.2   Methodology for identifying and rating impacts, risks and opportunities

From an operational standpoint, the double materiality exercise was carried out in two stages:

• identification of impacts, risks and opportunities relevant to Groupe BPCE’s business and its entire value chain;
• assessment of the materiality of these impacts, risks and opportunities.

Methodology for identifying impacts, risks and opportunities (IRO)

The IRO identification was carried out by topic and sub-topic according to the ESRS 1 requirements (AR 16):

• topics and sub-topics: the topics and sub-topics identification was carried out by mobilizing internal sources, such as the ESG matters identified in Groupe BPCE’s 2022 and 2023 NFPS reports, the reasonable due diligence process put in place by the Group as part of the Duty of Care plan and the existing risks mapping, supplemented by external sources, such as the analysis of a business sectors benchmark, with a focus on the most relevant matters for banking players. Following this identification of an initial list of topics and sub-topics, additional work was carried out to align with CSRD requirements. This alignment was carried out in two stages through workshops involving in-house business experts to (i) validate the list of topics and sub-topics according to these experts, and (ii) reconcile ESG issues with ESRS themes for the E, S and G components (AR 16 of ESRS 1). This work was carried out with the business lines in charge of the ESRS topics and sub-topics, drawing on the expertise of the employees of these teams;
• Impacts, Risks and Opportunities (IRO): work to identify the IRO within each theme was carried out in order to cover both impact materiality and financial materiality. Several internal and external sources were used to identify IROs;
• the relevance of each IRO was verified with the business lines concerned to ensure that the listed IRO effectively reflected a Risk, Opportunity or Impact for Groupe BPCE, to qualify the Impacts as positive or negative for the same sub-topic and to avoid duplication between similar IRO.

For each IRO identified, a rating was prequalified. This prequalification consisted of:

• a. positioning each IRO in Groupe BPCE’s value chain, i.e. upstream of its own activities, or downstream;
• b. defining the potential or actual nature of the negative and positive impacts.

Process for identifying and assessing impacts, risks and opportunities related to E2-Pollution, E3-Water and marine resources, E4-Biodiversity, E5-Resource use and circular economy.

The process of identifying the impacts of environmental matters, excluding climate change, at Groupe BPCE level was carried out across the entire value chain. Impacts have been identified on own operations as well as financing and asset management operations.

The rating of these impacts was conducted according to experts. As far as financing and asset management activities are concerned, the rating was carried out by experts based in particular on a business sectors analysis of Groupe BPCE’s exposures by the Group ESG Risk division as part of the scale assessment. This rating was strengthened by the mobilization of the Group’s stakeholders’ views.

The process of identifying and assessing environmental risks, excluding climate, is part of the same system as assessing the materiality of climate and environmental risks set up by Groupe BPCE.

With regard to opportunities, the identification and assessment process was carried out by experts taking into account economic changes related to environmental issues, excluding climate change, and Groupe BPCE’s outlook to adapt its banking, insurer and investor business models.

Consideration of the value chain in the identification of the Group’s IROs

The activities of Groupe BPCE and its entire upstream and downstream value chain were taken into account in the double materiality assessment. In light of Groupe BPCE’s business sector specific nature, the following guidelines have been adopted:

• a. map its activities and the stakeholders in the value chain to identify which stakeholders are in risky areas;
• b. carry out an analysis by major stakeholders families: customers, suppliers, subcontractors, etc...;
• c. enlarge this analysis beyond first-level and direct business relationships: the business lines took into consideration, in addition to the major families of direct stakeholders in the value chain, the entire environment surrounding them, in particular through sectors analysis. 

Organization in terms of identifying impacts, risks and opportunities

The identification of IROs was coordinated by and under the joint responsibility of Groupe BPCE’s Finance department, Financial Communication department and Impact department. The Retail Banking, Insurance, Architecture and Reporting, Risks, Purchasing, and Human Resources teams helped formalize and assess these IROs. 

Process for rating impacts, risks and opportunities

Following this first stage, among all the IROs identified as relevant, the impacts, risks and opportunities rating led to designate those that are material from an impact point of view or from a financial point of view, which are presented in this sustainability report.

Methodology for rating impacts, risks and opportunities

Description of the rating criteria

The ESRS impose criteria for assessing the materiality of IROs. These criteria may be different depending on whether one is related to an impact (negative or positive), a risk or an opportunity. 

1. The negative impacts are rated according to two dimensions:
   • i. likelihood this involves assessing the probability that Groupe BPCE will have a negative impact on the subject identified;
   • ii. severity composed of:
     1. Scale: the severity of the negative impact on people or the environment,
     2. Scope: the scope of the negative impacts. In the case of an environmental impact, the extent may refer to the extent of the damage caused to the environment or a geographic area. In the case of impacts on the population, the extent may refer to the number of people affected by the impact,
     3. Irremediable character: assessing whether, and to what extent, the negative impacts can be remediated.

     Note : In the event of a potential negative impact on human rights, the severity of the impact takes precedence over its likelihood.

2. The positive impacts are rated according to three dimensions:
   • i. likelihood: this involves assessing the probability that Groupe BPCE will have a positive impact on the subject identified;
   • ii. scale: the beneficial effect of the impact on people or the environment;
   • iii. scope: the extent of the impact (e.g. geographical or demographic).
3. The risks and opportunities are rated according to two dimensions:
   • i. likelihood of occurrence: probability of the risk or opportunity occurring;
   • ii. scale of the financial impact: measurement of the potential financial effects.

All IROs have been rated in gross terms, meaning without taking into account the action plans implemented by the group to prevent, mitigate, or remedy them. 

Rating scales

Rating scales are not prescribed by the ESRS. They have been defined by and for Groupe BPCE.  Each rating criterion was assessed on a scale from 1 to 4. 

Score and final rating of impacts, risks and opportunities

Each impact, risk and opportunity was rated, based on the criteria and scales described above. 

Determination of the materiality threshold

Materiality threshold refers to the score or rating based on which impacts, risks and opportunities are material. 

Groupe BPCE’s materiality threshold is defined by the CSRD Project Steering Committee.

Materiality threshold

As part of the harmonization of the rating scales defined for the criteria, a rating scale has also been defined for the rating level of impacts, risks and opportunities.

This scale consists of four levels:

An impact, risk or opportunity is material when the rating level is greater than or equal to 3, corresponding to a high or very high level. 

Organization in terms of rating impacts, risks and opportunities

Role of the Sustainability Office

The Sustainability Office  established the methodology for rating impacts, risks and opportunities on behalf of the Group. It also coordinated and supervised the IRO rating work on behalf of the Group. 

Operating procedure for rating IROs

Groupe BPCE’s Sustainability Office proposed the methodological approach for rating IROs as part of the CSRD Project. 

Workshops were held with the institutions (Banques Populaires and Caisses d’Epargne) as well as with the global business lines and BPCE Assurances to discuss structuring options for the rating of IROs and to co-construct a common approach. 

A Group operating procedure was prepared and shared with the representatives of the institutions (Banques Populaires, Caisses d’Epargne, BPCE) as well as with the subsidiaries.

Role of the functional departments

Several functional departments were called upon as part of the rating of the IROs. These notably include:

• the Purchasing department;
• the Compliance department;
• the Sustainability Office ;
• the Human Resources department;
• the ESG Risk department;
• the Operational Risk department;
• the Technology and Operations department.

Rating of Environmental Impacts via financing and investments

The rating of the environmental impacts in connection with financing and investments was carried out, according to experts, by the Sustainability Office, Retail Banking, BPCE Assurances and Natixis based on a business sectors analysis of Groupe BPCE’s exposures carried out by the Group Risk department as part of the assessment of the scale. This analysis focuses on the impact of 26 business sectors on various environmental matters (mitigation and adaptation to climate change, pollution, biodiversity, water and marine resources and the circular economy). A three-level scale is applied to each business sector depending on the criticality of its impact on each environmental matter:

• “strong” impact;
• “moderate” impact;
• “low” impact.

This information is used to score the “Scale” criterion of the negative impacts identified by Groupe BPCE:

1. No or very little impact when exposure to “strong impact” sectors is between 0% and 15%;
2. Significant: when exposure to “strong impact” sectors is between 15% and 50%;
3. High: when exposure to “strong impact” sectors is between 50% and 75%;
4. Very high: when the exposure to “strong impact” sectors exceeds 75%.

This rating was subject to additional reviews by experts in order to streamline the quantitative analysis and to cover all of the Group’s exposures, taking into account:

1. the scope of the environmental impacts of other sectors beyond the 26 business sectors analyzed by the ESG Risk department;
2. additional exposures to those obtained by the ESG Risk Department (exposures to individual retail, the public sector and exposures to financial institutions).

The other criteria, scope, irremediable character and likelihood were assessed on an expert basis taking into account the rating scales defined for all impacts.

Rating of environmental risks via financing and investments

The rating of environmental risks was carried out by the ESG Risk department on the basis of the materiality assessment of climate and environmental risks conducted annually by Groupe BPCE since 2021. The latter aims to qualify the materiality of climate and environmental, physical or transition, short-, medium- and long-term risks in relation to the “traditional” risks to which Groupe BPCE is exposed (according to the risk taxonomy defined within Groupe BPCE’s Risk Appetite Framework, e.g. credit risk, market risk, operational risk, etc.). This rating of environmental risks was based on an analysis of the impact of 26 business sectors regarding various environmental matters (mitigation and adaptation to climate change, pollution, biodiversity, water and marine resources and the circular economy).

This annual process is based on scientific knowledge (scenarios, assessment tools) and knowledge bases (e.g. Business Environment Scan), internal measures and indicators available at the date of completion of the exercise, as well as the expertise of all internal parties involved in the risk management system (LOD1 or LOD2). The assessments are carried out on the gross risk. This annual review is part of the continuous improvement of the underlying processes and methods.

As part of the assessment of the financial materiality of the CSRD risks, the assessment of the materiality of climate and environmental risks was cross-referenced with the materiality assessment of each of the “traditional” risks. This assessment is carried out annually as part of the work on the Risk Appetite Framework in order to obtain an assessment of the intrinsic materiality for each IRO on the same criteria as the other IROs (likelihood of occurrence / scale of impact), to ensure consistency between the different exercises. An expert’s overall consistency check was carried out to validate the materiality levels obtained.

To date, Groupe BPCE’s rating of environmental risks (biodiversity, water, pollution and circular economy) has been applied uniformly to all these environmental topics. The work undertaken by Groupe BPCE to strengthen the climate and environmental risk management system will gradually refine this analysis.

Process for validating the ratings of impacts, risks and opportunities

The validation of the IRO was carried out through workshops bringing together:

• representatives of the business lines concerned by each topic, subtopic and each Purchasing, Human Resources, Operational Risks IRO, etc.;
• sponsors of the institutions (4 Banques Populaires, 4 Caisses d’Epargne);
• the ESG Risk department;
• the CSR representatives of the global business lines, BPCE Assurances, Banque Palatine, BRED Banque Populaire, Crédit Coopératif, FSE and Digital & Payments;
• the Group Sustainability Office.

Stakeholder consultation process 

Although the consultation of stakeholders is not mandatory as part of the double materiality exercise, Groupe BPCE has deemed it important to specifically consult some of its stakeholders within the limits of this first exercise in addition to the existing permanent listening systems (see 1.3.2 - SBM-2). The ad hoc systems deployed concern customers, suppliers and cooperative shareholders and more than 300 members of the Group’s company boards.

1.5.1.1.3   Review process

In accordance with the CSRD transposed into French law, the sustainability report is prepared annually. As a result, and as specified by EFRAG in its guidance on double materiality, Groupe BPCE must determine the list of material IROs every year. If Groupe BPCE concludes, on the basis of audit evidence, that the results of the double materiality exercise for the previous year are still relevant at the reporting date, it may use the conclusions obtained previously for the preparation of the sustainability report.

Each year, Groupe BPCE will verify the elements that may trigger a revision of the list of material IRO, for example, a major merger and acquisition transaction leading to a new activity, an entry into a new sector or a significant change in operations, a global event (pandemic, natural disaster, etc.), a change in scientific evidence that could affect the severity criteria.

List of material IROs

1.5.2  SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

The material impacts, risks and opportunities (IRO) resulting from the double materiality assessment are listed in Section 1.5.1.1 (IRO-1). This description makes it possible to identify where in its business model, its own activities or its value chain these material IRO are concentrated.

The business model, value chain and integration of sustainability matters into Groupe BPCE’s strategy are detailed in Section 1.3.1.2 (SBM-1).

The interactions between these material impacts, risks and opportunities, the Group’s business model and its strategy embodied by the VISION 2030 strategic project, as well as the way in which positive or negative material impacts affect the company (customers, regional players or employees) or the environment are presented within each topical ESRS.

In the absence of established practices for financial institutions, are not published in respect of the 2024 fiscal year the financial effects relating to:

• material risks and opportunities of the company on its financial position, financial performance and cash flows;
• material risks and opportunities for which there is a risk of a significant adjustment to the carrying amount of assets and liabilities included in the financial statements during the next annual period.

With respect to climate risks, Groupe BPCE analyzes the resilience of its business model across its three activities (financing, insurance, asset management) through climate stress tests as part of the self-assessment process of its capital (ICAAP) and liquidity (ILAAP) adequacy with regard to the risks it may face. This analysis is presented in Chapter E1 - Climate change (Section 2.2.3.2.1).

1.5.3  IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s sustainability report

Disclosure Requirements in ESRS covered by the undertaking’s sustainability report.

ESRS 2 GOV-1

ESRS 2 GOV-4

ESRS 2 SBM-1

ESRS E1-1

ESRS E1-4

ESRS E1-5

ESRS E1-6

ESRS E1-7

ESRS E1-9

ESRS E2-4

ESRS E3-1

ESRS E3-4

ESRS 2 - SBM-3 - E4

ESRS E4-2

ESRS E5-5

ESRS 2 - SBM-3 - S1

ESRS S1-1

ESRS S1-3

ESRS S1-14

ESRS S1-16

ESRS S1-17

ESRS 2 - SBM-3 - S2

ESRS S2-1

ESRS S2-4

ESRS S3-1

ESRS S3-4

ESRS S4-1

ESRS S4-4

ESRS G1-1

ESRS G1-4

1. Regulation (EU) 2019/2088 of the European Parliament and of the Council of November 27, 2019 on sustainability reporting in the financial services sector (OJ L 317, December 9, 2019, p. 1).
2. Regulation (EU) 575/2013 of the European Parliament and of the Council of June 26, 2013 on prudential requirements for credit institutions and investment firms and amending Regulation (EU) 648/2012 (Capital Requirements Regulation - CRR) (OJ L 176, June 27, 2013, p. 1).
3. Regulation (EU) 2016/1011 of the European Parliament and of the Council of June 8, 2016 on the indices used as benchmarks for financial instruments and contracts or to measure the performance of investment funds and amending Directives 2008/48/EC and 2014/17/EU and Regulation (EU) 596/2014 (OJ L 171, June 29, 2016, p. 1).

Report on the certification of sustainability information and verification of the disclosure requirements under Article 8 of Regulation (EU) 2020/852 of Groupe BPCE

Year ended December 31, 2024

This is a translation into English of the statutory auditors’ report on the certification of sustainability information and verification of the disclosure requirements under Article 8 of Regulation (EU) 2020/852 of the Company issued in French and it is provided solely for the convenience of English speaking users.

This report should be read in conjunction with, and construed in accordance with, French law and the H2A guidelines on “Limited assurance engagement - Certification of sustainability reporting and verification of disclosure requirements set out in Article 8 of Regulation (EU) 2020/852”.

To the General Assembly

GROUPE BPCE

7, promenade Germaine Sablon

75013 PARIS

This report is issued in our capacity as statutory auditor of Groupe BPCE. It covers the sustainability information and the information required by Article 8 of Regulation (EU) 2020/852, relating to the year ended December 31, 2024 and included in the group management report and disclosed in section 2.1 “Groupe BPCE Sustainability report” in the chapter 2 of the universal registration document (below the “Groupe BPCE Sustainability report”).

Pursuant to Article L. 233-28-4 of the French Commercial Code, Groupe BPCE is required to include the above mentioned information in a separate section of the group management report. This information has been prepared in the context of the first time application of the aforementioned articles, a context characterized by uncertainties regarding the interpretation of the laws and regulations, the use of significant estimates, the absence of established practices and frameworks in particular for the double-materiality assessment, and an evolving internal control system. It enables an understanding of the impact of the activity of the group on sustainability matters, as well as the way in which these matters influence the development of the business of the group, its performance and position. Sustainability matters include environmental, social and corporate governance matters.

Pursuant to Article L.821-54 paragraph II of the aforementioned Code our responsibility is to carry out the procedures necessary to issue a conclusion, expressing limited assurance, on:

• compliance with the sustainability reporting standards adopted pursuant to Article 29 b of Directive (EU) 2013/34 of the European Parliament and of the Council of 14 December 2022 (hereinafter ESRS for European Sustainability Reporting Standards) of the process implemented by Groupe BPCE to determine the information reported, and compliance with the requirement to consult the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code;
• compliance of the sustainability information included in the Groupe BPCE Sustainability report with the requirements of Article L. 233-28-4 of the French Commercial Code, including ESRS; and
• compliance with the reporting requirements set out in Article 8 of Regulation (EU) 2020/852.

This engagement is carried out in compliance with the ethical rules, including independence, and quality control rules prescribed by the French Commercial Code.

It is also governed by the H2A guidelines on “Limited assurance engagement - Certification of sustainability reporting and verification of disclosure requirements set out in Article 8 of Regulation (EU) 2020/852”.

In the three separate sections of the report that follow, we present, for each of the sections of our engagement, the nature of the procedures that we carried out, the conclusions that we drew from these procedures and, in support of these conclusions, the elements to which we paid particular attention and the procedures that we carried out with regard to these elements. We draw your attention to the fact that we do not express a conclusion on any of these elements taken individually and that the procedures described should be considered in the overall context of the formation of the conclusions issued in respect of each of the three sections of our engagement.

Finally, where deemed necessary to draw your attention to one or more disclosures of sustainability information provided by Groupe BPCE in the group management report, we have included an emphasis of matter paragraph hereafter.

Limits of our engagement

As the purpose of our engagement is to express limited assurance, the nature (choice of techniques), extent (scope) and timing of the procedures are less than those required to obtain reasonable assurance.

Furthermore, this engagement does not provide guarantee regarding the viability or the quality of the management of Groupe BPCE, in particular it does not provide an assessment, of the relevance of the choices made by Groupe BPCE in terms of action plans, targets, policies, scenario analyses and transition plans, which would go beyond compliance with the ESRS reporting requirements.

It does, however, allow us to express conclusions regarding the entity’s process for determining the sustainability information to be reported, the sustainability information itself, and the information reported pursuant to Article 8 of Regulation (EU) 2020/852, as to the absence of identification or, on the contrary, the identification of errors, omissions or inconsistencies of such importance that they would be likely to influence the decisions that readers of the information subject to this engagement might make.

Any comparative information that would be included in the group management report are not covered by our engagement.

Compliance with the ESRS of the process implemented by Groupe BPCE to determine the information reported, and compliance with the requirement to consult the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code

Nature of procedures carried out

Our procedures consisted in verifying that:

• the process defined and implemented by Groupe BPCE has enabled it, in accordance with the ESRS, to identify and assess its impacts, risks and opportunities related to sustainability matters, and to identify the material impacts, risks and opportunities, that lead to the publication of information disclosed in the Groupe BPCE Sustainability report, and
• the information provided on this process also complies with the ESRS.

We also checked the compliance with the requirement to consult the social and economic committee.

Conclusion of the procedures carried out

On the basis of the procedures we have carried out, we have not identified any material errors, omissions or inconsistencies regarding the compliance of the process implemented by Groupe BPCE with the ESRS.

Concerning the consultation of the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code we inform you that as of the date of this report, this consultation has not yet been held.

Emphasis of matter

Without qualifying the conclusion expressed above, we draw your attention to the information provided in the note 1.1.2.3 “Sources of estimation and outcome uncertainty” which underlines  the uncertainty and limitations related to the methodologies used to perform the double materiality analysis regarding the thematic standards E2, E3, E4 and E5 (pollution, water and marine resources, biodiversity and ecosystems, and resource use and circular economy) for the year 2024.

Elements that received particular attention

We set out below the elements that have been the subject of particular attention in relation to our assessment of compliance with the ESRS of the process implemented by Groupe BPCE to determine the information reported.

• Concerning the identification of stakeholders

Information on the identification of stakeholders is set out in the note 1.3.2 “SBM2 – Interests and views of stakeholders” of the Groupe BPCE Sustainability report.

We interviewed management and others within the entity as appropriate and inspected available documentation.

We also assessed the consistency of the primary stakeholders identified by Groupe BPCE in view of the nature of its activities and its geographical location, taking into account its business relationships, its cooperative dimension and value chain.

• Concerning the identification of impacts, risks and opportunities

Information on the identification of impacts, risks and opportunities is provided in the note 1.5.1.1 “IRO-1 – Description of the identification and assessment of material impacts” of the Groupe BPCE Sustainability report.  

• We obtained an understanding of the process implemented by the entity to identify actual or potential impacts – both negative and positive – risks and opportunities (IROs), in relation to the sustainability matters mentioned in paragraph AR 16 of ESRS 1, “Application requirements”, and where applicable, those specific to Groupe BPCE, as presented in the above cited note.

In particular, we assessed the approach taken by the entity to determine its impacts and dependencies, which may be a source of risks or opportunities, including the dialogue undertaken, where appropriate, with stakeholders.

We obtained an understanding of the group’s mapping of identified IROs, including a description of their distribution within the group’s own operations and its value chain, as well as their time horizon (short, medium or long term), and assessed the consistency of this mapping with our knowledge of Groupe BPCE and, where applicable, with the risk analyses conducted by Groupe BPCE.  

• Concerning the assessment of impact materiality and financial materiality

Information on the assessment of impact materiality and financial materiality is provided in the note 1.5.1.1 “IRO-1 – Description of the identification and assessment of material impacts” the Groupe BPCE Sustainability report.

Through interviews with management and inspection of available documentation, we obtained an understanding of the process implemented by the entity to assess impact materiality and financial materiality, and assessed its compliance with the criteria defined in ESRS 1.

In particular, we assessed the way in which the entity established and applied the materiality criteria defined in ESRS 1, including those relating to the setting of thresholds, in order to determine the following material information reported:

• metrics relating to material IROs identified in accordance with the relevant ESRS standards;
• entity-specific disclosures.

Compliance of the sustainability information included in the Groupe BPCE Sustainability report with the requirements of Article L.233-28-4 of the French Commercial Code, including the ESRS

Nature of procedures carried out

Our procedures consisted in verifying that, in accordance with legal and regulatory requirements, including the ESRS:

• the disclosures provided enable an understanding of the general basis for the preparation and governance of the sustainability information included in the Groupe BPCE Sustainability report, including the basis for determining the information relating to the value chain and the exemptions from disclosures used;
• the presentation of this information ensures its readability and understandability;
• the scope chosen by Groupe BPCE for providing this information is appropriate; and
• on the basis of a selection, based on our analysis of the risks of non-compliance of the information provided and the expectations of users, that this information does not contain any material errors, omissions or inconsistencies, i.e. that are likely to influence the judgement or decisions of users of this information.

Conclusion of the procedures carried out

Based on the procedures we have carried out, we have not identified material errors, omissions or inconsistencies regarding the compliance of the sustainability information included in the Groupe BPCE Sustainability report, with the requirements of Article L.233-28-4 of the French Commercial Code, including the ESRS.

Emphasis of matter

Without qualifying the conclusion expressed above, we draw your attention to the information provided in the notes 1.1.2.3 “Sources of estimation and outcome uncertainty”, 2.2.3.1 “(E1-1) Transition plan for climate change mitigation” and 2.2.4.2 “(E1-6) Gross scopes 1,2, 3 and total GHG emissions”, which disclose the scope selected for the transition plan and for the calculation of financed emissions related to the value chain (category 15 of scope 3 according to the GHG Protocol) , as well as the limitations related to data availability, the assumptions used, and the methodologies applied to determine the estimates related to decarbonization targets and the greenhouse gas emissions balance.

Elements that received particular attention

• Information provided in application of the standards relating to general requirements and general disclosure (ESRS 1 – Climate change)

We set out below the elements that have been the subject of particular attention in relation to our assessment of compliance with the ESRS of the following information disclosed in the notes 2.2.3.1 “Transition plan for climate change mitigation” and 2.2.4 “Metrics and targets”. 

With regard to the information published on the greenhouse gas emissions (ESRS E1-6), as mentioned in the note 2.2.4.2 “(E1-6) Gross scopes 1,2,3 and total GHG emissions” of the Groupe BPCE Sustainability report, our work consisted primarily of:

• obtaining an understanding of the process, methods, frames, data and estimates used by Groupe BPCE to prepare the information (including procedures and internal control);
• with regard to Scope 3 emissions (categories 1, 2 and 6) regarding Groupe BPCE own operations:
  • assessing the appropriateness of the emission factors used and the calculation of the related conversions, taking into account the uncertainty inherent in the state of scientific or economic knowledge and the quality of the external data;
  • reconciling physical data, on a sample basis, to the underlying data used to draw up the greenhouse gas emissions assessment and tracing to supporting documents
• with regard to financed emissions (scope 3, category 15 of GHG Protocol) :
  • Understanding the scope of covered assets as described and assess its justification in regard of the applicable framework;
  • Verifying that the base used for computing financed emissions corresponds to the scope of covered assets as described in the note 2.2.4.2 and reconciling it with the consolidated general balance
  • assessing the appropriateness of the method for determining estimates, including the sectoral proxies chosen;
  • verifying the accuracy of the calculations used to prepare this information on a sample basis.

With regard to the information published on the Transition plan for climate change mitigation and adaptation (ESRS E1-1), as defined in the note 2.2.3.1 “(E1-1) Transition plan for climate change mitigation” of the Groupe BPCE Sustainability report, our work consisted primarily of:

• assessing the information related to the scope chosen for the Transition Plan (transition plan for own activities and sector-specific transition plans covering the value chain), as well as the processes, methodologies, frameworks, data, and estimates adopted by the Group to prepare the published information;
• assessing the description of the structural assumptions and reference climate scenarios underlying this plan, it being understood that we are not required to express a conclusion on the appropriateness or the level of ambition of the transition plan’s objectives ;
• assessing whether the transition plan reflects the commitments made by Groupe BPCE as stated in the minutes of its governance bodies’ meetings and other group communications;;
• assessing whether the transition plan is in line with the strategic plan as approved by the governing bodies and the financial planning of Groupe BPCE;
• assessing the information related to the scope chosen for the analysis of transition risks (physical and transition risks), as well as the methodologies, scenarios, and assumptions adopted by the group, and their integration into risk mapping of the Group.

Compliance with the reporting requirements set out in Article 8 of Regulation (EU) 2020/852

Nature of procedures carried out

Our procedures consisted in verifying the process implemented by Groupe BPCE to determine the eligible and aligned nature of the activities of the entities included in the consolidation.

They also involved verifying the information reported pursuant to Article 8 of Regulation (EU) 2020/852, which involves checking:

• the compliance with the rules applicable to the presentation of this information to ensure that it is readable and understandable;
• on the basis of a selection, the absence of material errors, omissions or inconsistencies in the information provided, i.e. information likely to influence the judgement or decisions of users of this information.

Conclusion of the procedures carried out

Based on the procedures we have carried out, we have not identified any material errors, omissions or inconsistencies relating to compliance with the requirements of Article 8 of Regulation (EU) 2020/852.

Emphasis of matters

Without qualifying the conclusion expressed above, we draw your attention to:

• The information in the paragraph “Methodology used” in the note 2.1 “Indicators of the European taxonomy on sustainable activities” which discloses the main methodological assumptions used to assess the alignment of loans granted to individuals
• The information in the paragraph “Assumptions used and existing limitations in the preparation and collection of information” in the note 2.1 “Indicators of the European taxonomy on sustainable activities” which discloses the main existing limitations in the presentation of information, including those concerning the presentation of cash flow information regarding the KPI on off-balance-sheet exposures.

Elements that received particular attention

We concluded that there are no elements that received particular attention to report.

Done at Neuilly-sur-Seine and Paris La Défense, March 21, 2025

The statutory auditors

French original signed by

Introductory remarks

The following sustainability report is the result of a regulatory obligation imposing a publication on a scope covering only BPCE, which is made up of the central institution of Groupe BPCE, the business lines serving the activities of the Banque Populaire and Caisse d’Epargne networks, Natixis SA, as well as resource pools.

The analysis of the double materiality for the two scopes is identical. The criteria for identifying impacts, risks and opportunities (IRO) and assessing their materiality are the same. The same applies to the definition of policies and action plans.

This is why this report makes references to Groupe BPCE’s sustainability report for elements of strategy and editorial content.

This report presents certain quantitative metrics required by the standard, when they are applicable to the BPCE scope.

Where applicable, the reported quantitative metrics are calculated for the BPCE scope. This concerns a majority of the indicators required by the ESRS.

The indicators required by the ESRS that are not applicable to BPCE concern:

• greenhouse gas emission reduction targets: these are calculated solely for Groupe BPCE scope, as an integral part of the transition strategy covering the entire Group scope;
• indicators relating to the G1-3 and G1-4 topics, which are calculated for the scope of Groupe BPCE only.

These items are published in Groupe BPCE’s report, which includes the BPCE scope.

1.1.1     BP-1 - General basis for the preparation of the sustainability statements

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2     BP-2 - Disclosures in relation to specific circumstances

1.1.2.1     TIME HORIZONS

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.2     VALUE CHAIN ESTIMATION

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.3     SOURCES OF ESTIMATION AND OUTCOME UNCERTAINTY

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.4     CHANGES IN PREPARATION OR PRESENTATION OF SUSTAINABILITY INFORMATION

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.5     REPORTING OF ERRORS IN PRIOR PERIODS

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.6     DISCLOSURES STEMMING FROM OTHER LEGISLATION OR GENERALLY ACCEPTED SUSTAINABILITY REPORTING PRONOUNCEMENTS

See the corresponding section in Groupe BPCE’s sustainability report.

1.1.2.7     INCORPORATION BY REFERENCE

See the corresponding section in Groupe BPCE’s sustainability report.

1.2.1    SBM-1 - Strategy, business model and value chain

See the corresponding section in Groupe BPCE’s sustainability report.

1.2.2    SBM-2 - Interests and views of stakeholders

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.1    GOV-1 - The role of the administrative, management and supervisory bodies

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.1.1   COMPOSITION AND DIVERSITY OF BPCE’S MANAGEMENT AND SUPERVISORY BODIES

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.2    GOV-2-Information provided to and sustainability matters addressed by the undertaking’s administrative, management and supervisory bodies

1.3.2.1   SUSTAINABILITY TOPICS ADDRESSED BY THE ADMINISTRATIVE, MANAGEMENT AND SUPERVISORY BODIES

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.3   GOV-3 - Integration of sustainability-related performance in incentive schemes

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.4   GOV-5 - Risk management and internal controls over sustainability reporting

See the corresponding section in Groupe BPCE’s sustainability report.

1.3.5   GOV-4 - Statement on due diligence

See the corresponding section in Groupe BPCE’s sustainability report.

1.4.1     IRO-1 - Description of the processes to identify and assess material impacts, risks and opportunities

See the corresponding section in Groupe BPCE’s sustainability report.

1.4.2     SBM-3 - Material impacts, risks and opportunities and their interaction with strategy and business model

See the corresponding section in Groupe BPCE’s sustainability report.

1.4.3     IRO-2 - Disclosure Requirements in ESRS covered by the undertaking’s sustainability statements

See the corresponding section in Groupe BPCE’s sustainability report.

Report on the certification of sustainability information and verification of the disclosure requirements under Article 8 of Regulation (EU) 2020/852

Year ended December 31, 2024

This is a translation into English of the statutory auditors’ report on the certification of sustainability information and verification of the disclosure requirements under Article 8 of Regulation (EU) 2020/852 of the Company issued in French and it is provided solely for the convenience of English speaking users.

This report should be read in conjunction with, and construed in accordance with, French law and the H2A guidelines on “Limited assurance engagement - Certification of sustainability reporting and verification of disclosure requirements set out in Article 8 of Regulation (EU) 2020/852”.

To the General Assembly

BPCE

7, promenade Germaine Sablon

75013 PARIS

This report is issued in our capacity as statutory auditors of BPCE group. It covers the sustainability information and the information required by Article 8 of Regulation (EU) 2020/852, relating to the year ended December 31, 2024 and included in section 2.3 “BPCE Sustainability report” in the chapter 2 of the universal registration document (below “BPCE Sustainability report”).

Pursuant to Article L. 233-28-4 of the French Commercial Code, BPCE is required to include the above mentioned information in a separate section of the group management report. This information has been prepared in the context of the first time application of the aforementioned articles, a context characterized by uncertainties regarding the interpretation of the laws and regulations, the use of significant estimates, the absence of established practices and frameworks in particular for the double-materiality assessment, and an evolving internal control system. It enables an understanding of the impact of the activity of the group on sustainability matters, as well as the way in which these matters influence the development of the business of the group, its performance and position. Sustainability matters include environmental, social and corporate governance matters.

Pursuant to Article L.821-54 paragraph II of the aforementioned Code our responsibility is to carry out the procedures necessary to issue a conclusion, expressing limited assurance, on:

• compliance with the sustainability reporting standards adopted pursuant to Article 29 b of Directive (EU) 2013/34 of the European Parliament and of the Council of 14 December 2022 (hereinafter ESRS for European Sustainability Reporting Standards) of the process implemented by BPCE to determine the information reported, and compliance with the requirement to consult the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code;
• compliance of the sustainability information included in BPCE Sustainability report included the group management report with the requirements of Article L. 233-28-4 of the French Commercial Code, including ESRS; and
• compliance with the reporting requirements set out in Article 8 of Regulation (EU) 2020/852.

This engagement is carried out in compliance with the ethical rules, including independence, and quality control rules prescribed by the French Commercial Code.

It is also governed by the H2A guidelines on “Limited assurance engagement - Certification of sustainability reporting and verification of disclosure requirements set out in Article 8 of Regulation (EU) 2020/852”.

In the three separate sections of the report that follow, we present, for each of the sections of our engagement, the nature of the procedures that we carried out, the conclusions that we drew from these procedures and, in support of these conclusions, the elements to which we paid particular attention and the procedures that we carried out with regard to these elements. We draw your attention to the fact that we do not express a conclusion on any of these elements taken individually and that the procedures described should be considered in the overall context of the formation of the conclusions issued in respect of each of the three sections of our engagement.

Finally, where deemed necessary to draw your attention to one or more disclosures of sustainability information provided by BPCE in the BPCE Sustainability report, we have included an emphasis of matter paragraph hereafter.

Limits of our engagement

As the purpose of our engagement is to express limited assurance, the nature (choice of techniques), extent (scope) and timing of the procedures are less than those required to obtain reasonable assurance.

Furthermore, this engagement does not provide guarantee regarding the viability or the quality of the management of BPCE, in particular it does not provide an assessment, of the relevance of the choices made by BPCE in terms of action plans, targets, policies, scenario analyses and transition plans, which would go beyond compliance with the ESRS reporting requirements.

It does, however, allow us to express conclusions regarding the entity’s process for determining the sustainability information to be reported, the sustainability information itself, and the information reported pursuant to Article 8 of Regulation (EU) 2020/852, as to the absence of identification or, on the contrary, the identification of errors, omissions or inconsistencies of such importance that they would be likely to influence the decisions that readers of the information subject to this engagement might make.

Any comparative information that would be included in the group management report are not covered by our engagement.

Compliance with the ESRS of the process implemented by BPCE to determine the information reported, and compliance with the requirement to consult the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code

Nature of procedures carried out

Our procedures consisted in verifying that:

• the process defined and implemented by BPCE has enabled it, in accordance with the ESRS, to identify and assess its impacts, risks and opportunities related to sustainability matters, and to identify the material impacts, risks and opportunities, that lead to the publication of information disclosed in the BPCE Sustainability report, and
• the information provided on this process also complies with the ESRS.

We also checked the compliance with the requirement to consult the social and economic committee.

Conclusion of the procedures carried out

On the basis of the procedures we have carried out, we have not identified any material errors, omissions or inconsistencies regarding the compliance of the process implemented by BPCE with the ESRS.

Concerning the consultation of the social and economic committee provided for in the sixth paragraph of Article L. 2312-17 of the French Labour Code we inform you that as of the date of this report, this consultation has not yet been held.

Emphasis of matter

Without qualifying the conclusion expressed above, we draw your attention to the information provided in:

• the paragraph “Introductory remarks” of the BPCE Sustainability report, which recalls the existence of two scopes for publishing sustainability information (BPCE and Groupe BPCE) and the reasons why the sustainability report for the BPCE scope refers to the sustainability report of the Groupe BPCE scope, as well as the modalities of these references, and specifies that the double materiality analysis for these two scopes is identical.
• paragraph 1.1.2.3 “Sources of estimation and outcome uncertainty” which refers to the corresponding section in the Groupe BPCE Sustainability report, for which we make the same observation as for the Groupe BPCE scope, concerning the uncertainty and limitations related to the methodologies used to perform the double materiality analysis regarding the thematic standards E2, E3, E4, and E5 (pollution, aquatic and marine resources, biodiversity and ecosystems, and resource use and circular economy) for the year 2024

Elements that received particular attention

We set out below the elements that have been the subject of particular attention in relation to our assessment of compliance with the ESRS of the process implemented by BPCE to determine the information reported.

• Concerning the identification of stakeholders

Information on the identification of stakeholders is set out in section 1.2.2 SBM-2 - Interests and views of stakeholders of the BPCE Sustainability report.

We interviewed management and others within the entity as appropriate and inspected available documentation.

We also assessed the consistency of the primary stakeholders identified by BPCE in view of the nature of its activities and its geographical location, taking into account its business relationships, its cooperative dimension and value chain

• Concerning the identification of impacts, risks and opportunities

Information on the identification of impacts, risks and opportunities is provided in section 1.4.1 “IRO-1 - Description of the processes to identify and assess material impacts, risks and opportunities” of the BPCE Sustainability report.  

We obtained an understanding of the process implemented by BPCE to identify actual or potential impacts – both negative and positive –risks and opportunities (IROs), in relation to the sustainability matters mentioned in paragraph AR 16 of ESRS 1, “Application requirements”, and where applicable, those specific to BPCE, as presented in the above cited note.

In particular, we assessed the approach taken by BPCE to determine its impacts and dependencies, which may be a source of risks or opportunities, including the dialogue undertaken, where appropriate, with stakeholders.

We obtained an understanding of the group’s mapping of identified IROs, including a description of their distribution within the group’s own operations and its value chain, as well as their time horizon (short, medium or long term), and assessed the consistency of this mapping with our knowledge of BPCE group and, where applicable, with the risk analyses conducted by BPCE.  

• Concerning the assessment of impact materiality and financial materiality

Information on the assessment of impact materiality and financial materiality is provided in section 1.4.1 “IRO-1 - Description of the processes to identify and assess material impacts, risks and opportunities” of the BPCE Sustainability report. 

Through interviews with management and inspection of available documentation, we obtained an understanding of the process implemented by the entity to assess impact materiality and financial materiality, and assessed its compliance with the criteria defined in ESRS 1.

In particular, we assessed the way in which BPCE established and applied the materiality criteria defined in ESRS 1, including those relating to the setting of thresholds, in order to determine the following material information reported:

• metrics relating to material IROs identified in accordance with the relevant ESRS standards;
• entity-specific disclosures.

Compliance of the sustainability information included in BPCE Sustainability report with the requirements of Article L.233-28-4 of the French Commercial Code, including the ESRS

Nature of procedures carried out

Our procedures consisted in verifying that, in accordance with legal and regulatory requirements, including the ESRS:

• the disclosures provided enable an understanding of the general basis for the preparation and governance of the sustainability information included in BPCE Sustainability report, including the basis for determining the information relating to the value chain and the exemptions from disclosures used
• the presentation of this information ensures its readability and understandability;
• the scope chosen by BPCE for providing this information is appropriate; and
• on the basis of a selection, based on our analysis of the risks of non-compliance of the information provided and the expectations of users, that this information does not contain any material errors, omissions or inconsistencies, i.e. that are likely to influence the judgement or decisions of users of this information

Conclusion of the procedures carried out

Based on the procedures we have carried out, we have not identified material errors, omissions or inconsistencies regarding the compliance of the sustainability information included in BPCE Sustainability report, with the requirements of Article L.233-28-4 of the French Commercial Code, including the ESRS.  

Emphasis of matter

Without qualifying the conclusion expressed above, and in connection with the statement made above regarding the paragraph “Introductory remarks” concerning the scope of publication of sustainability information for BPCE and Groupe BPCE, we draw your attention to:

• the paragraph “Introductory remarks”, which specifies that the greenhouse gas emission reduction targets are calculated only for the Groupe BPCE scope, as an integral part of the transition strategy covering the entire group scope;paragraph 2.2.4.2 “(E1-6) gross scopes 1, 2, 3 and total ghg emissions” which outlines the calculation of financed emissions related to the value chain (category 15 of scope 3 according to the GHG protocol) as well as the limitations related to data availability, assumptions used, and methodologies applied to determine estimates related to decarbonization targets and the greenhouse gas emissions balance.

Elements that received particular attention

• Information provided in application of the standards relating to general requirements and general disclosure (ESRS 1 – Climate change))

We set out below the elements that have been the subject of particular attention in relation to our assessment of compliance with the ESRS of the following information disclosed in the paragraphs 2.2.3.1 “(E1-1) Transition plan for climate change mitigation” and 2.2.4 “Metrics and targets”.

With regard to the information published on the greenhouse gas emissions (ESRS E1-6), as mentioned in the paragraph 2.2.4.2 “(E1-6) Gross scopes 1, 2, 3 and total ghg emissions”, our work consisted primarily of:

• obtaining an understanding of the process, methods, frames, data and estimates used by BPCE to prepare the information (including procedures and internal control);
• with regard to Scope 3 emissions (categories 1, 2 and 6) regarding BPCE own operations:
  • assessing the appropriateness of the emission factors used and the calculation of the related conversions, taking into account the uncertainty inherent in the state of scientific or economic knowledge and the quality of the external data;
  • reconciling physical data, on a sample basis, to the underlying data used to draw up the greenhouse gas emissions assessment and tracing to supporting documents
• with regard to financed emissions(scope 3, category 15 of GHG Protocol) :
  • Understanding the scope of covered assets as described and assess its justification in regard of the applicable framework
  • Verifying that the base used for computing financed emissions corresponds to the scope of covered assets as described in note 2.2.4.2 and reconciling it with the consolidated general balance
  • assessing the appropriateness of the method for determining estimates, including the sectoral proxies chosen;
  • verifying the accuracy of the calculations used to prepare this information on a sample basis.

Compliance with the reporting requirements set out in Article 8 of Regulation (EU) 2020/852

Nature of procedures carried out

Our procedures consisted in verifying the process implemented by BPCE to determine the eligible and aligned nature of the activities of the entities included in the consolidation.

They also involved verifying the information reported pursuant to Article 8 of Regulation (EU) 2020/852, which involves checking:

• the compliance with the rules applicable to the presentation of this information to ensure that it is readable and understandable;
• on the basis of a selection, the absence of material errors, omissions or inconsistencies in the information provided, i.e. information likely to influence the judgement or decisions of users of this information.>

Conclusion of the procedures carried out

Based on the procedures we have carried out, we have not identified any material errors, omissions or inconsistencies relating to compliance with the requirements of Article 8 of Regulation (EU) 2020/852.

Emphasis of matters

Without qualifying the conclusion expressed above, and in connection with the statement made above regarding the paragraph “Introductory remarks” concerning the scope of publication of sustainability information for BPCE and Groupe BPCE, we draw your attention to the information in paragraph 2.1 “Indicators of the European taxonomy on sustainable activities” of the BPCE Sustainability report, which refers to sections 2.1 and 5 “Indicators of the European taxonomy on sustainable activities” of the Groupe BPCE Sustainability Report, for which we make the same statements as for the Groupe BPCE scope, regarding:

• the main methodological assumptions used to assess the alignment of loans granted to individuals;
• the main existing limitations in the presentation of information, including those concerning the presentation of cash flow information regarding the KPI on off-balance-sheet exposures.

Elements that received particular attention

We concluded that there are no elements that received particular attention to report.

Done at Neuilly-sur-Seine and Paris La Défense, March 21, 2025

The statutory auditors
French original signed by