BPCE_URD_EN 2025

This Universal Registration Document was filed on March 19, 2026 with the AMF, in its capacity as the competent authority in respect of Regulation (EU) No. 2017/1129, without prior approval pursuant to Article 9 of said regulation. The Universal Registration Document may only be used for the purposes of a public offering or admission of securities to trading on a regulated market if it is accompanied by a memorandum pertaining to the securities and, where applicable, an executive summary and all amendments made to the Universal Registration Document. The complete package of documents is approved by the AMF in accordance with Regulation (EU) No. 2017/1129.

Copies of this Universal Registration Document may be obtained free of charge from BPCE, 7, Promenade Germaine Sablon 75013 Paris.

The English version of this report is a free translation from the original which was prepared in French. All possible care has been taken to ensure that the translation is an accurate presentation of the original. However, in matters of interpretation, views or opinions expressed in the original language version of the document in French take precedence over the translation. Only the French version of the Universal Registration Document has been submitted to the AMF. It is therefore the only version that is binding in law.

Groupe BPCE at a glance

Groupe BPCE is the No. 2 banking group(1) in France and finances over 21%(2) of the French economy. All our customers, be they individuals, professionals, associations, corporate customers of all sizes or institutional customers, have constantly evolving expectations, with increasing demands in terms of availability, feedback, advice and service.

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

In the regions and internationally, our brands support our clients in all their projects, through all distribution channels, by offering them a complete range of financial services and offers.

Thanks to its unlisted cooperative nature, which enables it to invest to meet the challenges of tomorrow, Groupe BPCE is committed to long-term action and provides local and concrete responses to economic and societal transformations. Its cooperative model is a performance factor, in line with society’s expectations.

• ⁽¹⁾ Market shares: 22.06% in customer savings and 21.19% in customer loans (Banque de France Q3 2025 all non-financial customer categories).
• ⁽²⁾ 21.19% market share in outstanding loans, all non-financial sector customers (Banque de France Q3 2025).

• ⁽¹⁾ 2025 Kantar SME SMI survey.
• ⁽²⁾ Observatoire de la dette Finance Active des Collectivités Locales at the end of 2024 and Observatoire Finance Active de la dette des bailleurs sociaux.
• ⁽³⁾ 37.9% penetration rate among professional customers and individual entrepreneurs (Pépites CSA 2023-2024 survey).
• ⁽⁴⁾ Athling #laminutecreditconso study (2024).
• ⁽⁵⁾ L’Argus de l’assurance 2024.
• ⁽⁶⁾ IPE Top 500 Asset Managers 2025 Report.
• ⁽⁷⁾ Dealogic.
• ⁽⁸⁾ Dealogic.

Groupe BPCE has opened a new chapter in its history with the launch of its VISION 2030 strategic project. Outlining the main strategic priorities of the Group and its business lines between now and 2030, this project is resolutely focused on the growth and diversification of its activities. It has commercial, financial and non-financial objectives for 2026 that already capitalize on several ambitious projects announced from 2024.

True to its cooperative nature, Groupe BPCE has mobilized the 14 Banques Populaires, the 15 Caisses d’Epargne and BPCE’s business lines, in order to build a growth project to serve its clients in a society marked by four major transitions: environmental, demographic, technological and geopolitical. The acceleration and mutual reinforcement of these transitions may generate uncertainty. 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.

Our markers

A new growth sequence

In response to the climate emergency, our 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 of climate change.

Making the impact accessible to all means raising awareness and providing extensive support to our customers in the environmental transition by providing them with expertise, advisory services, and comprehensive solutions:

• Supporting energy renovation and the adaptation of housing to aging and loss of autonomy by offering financing solutions and by mobilizing our role as an operator, trusted third party as well as our partnerships;
• Supporting the transition of business models from SMEs to the largest international companies with a dedicated local dialog and a contribution of sector expertise to integrate ESG issues according to their size and economic sector;
• Offering sustainable savings and investment solutions through a range of responsible investments;
• Supporting the evolution of the energy mix, particularly in the development of renewable and low-carbon energies;
• Aligning our financing and insurance portfolios with trajectories based on scientific scenarios compatible with the objectives of the Paris Agreement;
• Working to reduce the pressure on nature and gradually integrate the protection of biodiversity into our activities.

Stemming from century-old brands in close contact to territories and the needs of both customers and society, our companies have played a societal role since their origins:

• 1^st bank for SMEs, we are also a leading financer of the Social and Solidarity Economy;
• A key player in solidarity finance and social entrepreneurship;
• A long-standing partner in social housing;
• Support for the most vulnerable populations with adapted products and services, and economic empowerment of everyone through action and acculturation programs.

In the regions, the Banques Populaires and the Caisses d’Epargne are key players in the dynamic development of our territories by financing the construction or renovation of infrastructure and facilities necessary for education, health or mobility. They are the leading private financer of local authorities and the hospital sector. Globally, Natixis Investment Managers and Natixis Corporate & Investment Banking are developing their Asset & Wealth Management and Corporate & Investment Banking business lines in more than 40 countries in compliance with international commitments, in terms of investment and financing.

The sponsorship of the 14 Banques Populaires is measured each year via their Cooperative and Societal Footprint, which identifies and values in euros the CSR and cooperative actions implemented within each bank.

Created by philanthropists, the Caisses d’Epargne have been working to promote social cohesion and the fight against exclusion since their inception. They support structures of general interest in various fields: housing, solidarity, biodiversity, financial inclusion, financial education, heritage.

Innovative in Sustainable Finance, the Group has set a target of issuing more than five green, social or health financing instruments per year, using all the debt instruments at its disposal.

In order to support our clients’ transitions, with in-depth expertise and taking into account new market methodologies, we have launched an internal transformation plan for all Group companies at every level.

This pragmatic, shared and managed impact approach enables Groupe BPCE to operate as a banker, insurer and investor in the service of all its customers, bringing economic, societal and environmental performance to the heart of the territories and regions of the world where it is present.

Governance

Composition of the Supervisory Board

7 representatives of the Banques Populaires

7 representatives of the Caisses d’Epargne

3 independent members

2 employee representatives

6 non-voting directors (as advisors)

Supervisory Board members’ expertise*

Skills for which the average level of all Board members is higher than 4/5

• – Banking and financial markets
• – Accounting and audit
• – Assessment of the effectiveness of the systems
• – Strategic planning
• – Legal requirements and regulatory framework
• – AML-CTF
• – Risk management
• – Social and solidarity economy
• – Cooperative banking experience
• – The Group’s business lines
• – Regional specificities
• – Economic and regional environment
• – Human Resources
• – Interpretation of the financial information of a credit institution, identification of the main issues on the basis of this information and appropriate controls and measures

Skills for which the average level of all Board members is lower than 4/5

• – Knowledge and experience of climate and environmental risks
• – International
• – Information systems and digital

Management Board

• * The average skill levels of Board members are detailed in the Supervisory Board’s collective skills matrix, Section 4.4.2 of this Universal Registration Document.

A solid Group generating robust performances

A recurring and diversified revenue base

Business line contribution to NBI in 2025 (in %)

Business line contribution to income before tax in 2025 (in %)

Activity (in billions of euros)

Prudential ratio (in %)

Liquidity reserves (in billions of euros)

Ratings as of December 31, 2025

Long-and short-term ratings

The ratings concern BPCE and also apply to Groupe BPCE.

Non-financial ratings 2025

Key non-financial figures

BPCE indicators¹

• 1 BPCE includes BPCE SA and its subsidiaries. The Banques Populaires and Caisses d’Epargne do not contribute to the results of BPCE.

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

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

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

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

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

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

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

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

• ⁽¹⁾ Fédération Nationale des Banques Populaires
• ⁽²⁾ Indirectly through local savings companies (LSCs)
• ⁽³⁾ Fédération Nationale des Caisses D’Epargne
• ⁽⁴⁾ 50.1% owned
• ⁽⁵⁾ Indirectly through Natixis SA

Group architecture

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

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

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

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

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

SEE CHAPTER 4

“REPORT ON CORPORATE GOVERNANCE”

BPCE brings together the central institution of Groupe BPCE, the retail and global business lines, as well as the resource pools. To support the Group’s performance, development and strategic ambitions, BPCE ensures the coordination, consistency and synergies between its various brands and companies.

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

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

• – coordinate trade policies;
• – represent the Group and its networks, and negotiate national/international agreements on their behalf;
• – represent the Group and its networks as an employer;
• – take all necessary measures to ensure the Group’s liquidity and solvency, risk management and internal control.

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

• Beyond the central institution, BPCE brings together the following business lines, to serve the Group’s development:

• – Insurance
• – Digital & Payments
• – Financial Solutions & Expertise
• – BPCE Technologies & Opérations
• – Corporate & Investment Banking
• – Asset & Wealth Management

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

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

REFER TO CHAPTER 1

“PRESENTATION OF GROUPE BPCE”

1.4.1 Retail Banking and Insurance

Banques Populaires

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

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

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

Measured and recognized commitments

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

Individual customers

2025 was marked by a significant recovery in the real estate market, with a +55% increase in new home loans at the end of December compared to the previous year for the entire Banque Populaire network. This surge in activity led to a +1% increase in new relationships. In consumer loans, sustained growth of +4.4% in commitments was observed at the end of December 2025. The number of principal active clients also continued to grow, reaching 4.8 million at the end of December 2025, with more than 2 million clients equipped with the Cristal agreement, a bundled offer of products and services for day-to-day current account management launched in 2019.

In terms of digital tools, 3.7 million clients are equipped with remote banking and enrolled in Sécur’Pass. Over the last three months, 93% of clients who made online payments were equipped with Sécur’Pass, demonstrating their commitment to digital services.

However, despite the recovery in real estate loans, the non-life insurance (IARD) and personal protection insurance sector recorded a 2% decline in gross sales at the end of December.

In 2025, several initiatives were launched to strengthen the commitment of the Banques Populaires to the energy transition and sustainability. The launch of the Impact Home Loan allows clients to obtain an interest rate reduction if they improve the energy performance of their homes. The Banques Populaires have supported nearly 18,500 clients in their energy renovation projects, with an amount of financing of €332 million, up 19% compared to 2024.

Impact home insurance was launched to encourage eco-responsible policyholder behavior.

In collaboration with Cozynergy, a free energy renovation diagnosis is now available, facilitating clients’ access to grants and subsidies.

The Zero Interest Plus Loan (PTZ+X) was renewed to support home ownership for young first-time buyers, while an innovative financing solution, the reverse mortgage, was offered to clients over 60.

Lastly, numerous initiatives aimed at young people, in terms of education, entrepreneurship or financial accessibility were carried out.

• – As part of its partnership with the Cnam, Banque Populaire has developed a program specifically designed to support young entrepreneurs.
• – To support students with the rising cost of living, Banque Populaire launched a student loan with no personal guarantee or means testing. This scheme aims to help more than 50,000 students in France.
• – Banque Populaire has also reinvented its mobile application for teenagers, allowing young people to manage their money independently while reassuring their parents thanks to a supervision interface.

In November, Banque Populaire launched a comprehensive and attractive banking offer aimed at 18-25 year-olds for just €2 a month.

Finally, the “EXTRA +X” loyalty program, which is free and non-binding, rewards the loyalty of cooperative shareholders and clients by enabling them to save money throughout the year.

Professional clients

In an uncertain economic and political environment, the Banques Populaires have reaffirmed their commitment to all professionals: craftspeople, retailers, liberal professions and farmers, throughout their career: creation, development, transfer and transmission. They recorded a positive development in terms of winning new clients:

• Agriculture and wine growing: +5.6% (excluding BRED and Crédit Coopératif)
• Healthcare: +4.4% (excluding BRED and Crédit Coopératif)
• Franchising: +3.4% (excluding BRED and Crédit Coopératif)

This momentum is accompanied by an increase in bank and financial savings inflows, thus strengthening the strength of the Banques Populaires’ balance sheets. In addition, sales of electronic payment solutions for merchants also increased, as did the stock of business cards.

Medium- and long-term loan financing grew by +13.8%, as well as leasing at +22%, underlining the commitment of the Banques Populaires to supporting professionals in their projects, even in a context of uncertainty.

In addition, demand for insurance (multi-risk and automotive) maintained a sustained pace, with strong growth in the number of new employee savings contracts (+11%), meeting the needs of preparing for retirement and retaining company employees in a context of labor shortage.

Client satisfaction also improved, with an NPS reaching +22, reflecting the daily support of the Banques Populaires’ Pro advisors.

In 2025, the Banques Populaires demonstrated an ongoing commitment to professionals, through various initiatives tailored to their specific needs.

A new invoice management service was launched via the online platform, operated by iPaidThat. This service, accessible free of charge, enables professional clients to anticipate the regulations on electronic invoicing coming into force in September 2026. Professionals can thus optimize their cash flow, shorten payment times and simplify the collection of accounting documents.

Several specific initiatives have been put in place to support the agricultural sector:

• – Impact loan to professionals and farmers: expansion to enhance their CSR commitments. This loan promotes their transition to sustainable practices and offers advantageous financing conditions.
• – “Nouvel Installé en Agriculture” loan: preferential rate of 1.90% with a budget of €100 million to finance the installation of new farmers and winegrowers.
• – White Paper: a practical guide on wealth building in agriculture, co-produced with La France Agricole.
• – French Agriculture Initiative Program (INAF): free guarantee instrument to support the creation of added value and generational renewal in the sector.

Already a long-standing partner of many professional health organizations (Fédération Nationale des Infirmiers, Fédération Française des Masseurs Kinésithérapeutes Rééducateurs), in 2025, Banque Populaire formed a partnership with the Union des Syndicats de Pharmaciens d’Officine and launched the “Forfait Monétique Santé” to facilitate the collection of credit card fees. In addition, through its NextSanté network, it helps to boost healthcare innovation, fight against medical deserts and improve access to local care for all.

Communication

2025 was marked by active communication among professionals and companies, notably through a powerful radio communication system, the presence at more than 17 events and a notable acceleration on social networks with, for example, the successful launch of a TikTok account to target young entrepreneurs. Unveiled in December 2024, the new Banque Populaire brand film, based on a vision of success that radiates with a positive impact on our regions, was broadcast throughout the year on television, in VOL and in cinemas. The year was also marked by the first institutional communication for Banque Populaire. Through a campaign in the national daily press, Banque Populaire illustrated its role as a source of vitality for the regions. In November and December, Banque Populaire communicated with young people about its new offer dedicated to 18-25 year olds, with a large-scale display, social network and influence system. In addition, the brand has reaffirmed its commitment until 2029 as a shipowner, partner and patron in the world of sailing and surfing, notably with the announcement of the construction of an IMOCA to take part in the 2028 Vendée Globe. Banque Populaire has also signed up alongside Armel Le Cléach’ and Sébastien Josse in the Transat Café l’Or. Lastly, Banque Populaire also launched its Act for Water initiative and raised awareness of its preservation through various communication actions with the general public.

Crédit Coopératif

As a reference bank for the social and solidarity economy, real economy companies and committed individual customers, Crédit Coopératif is committed alongside its client-cooperative shareholders to build a fairer, more inclusive, more local economy that is respectful of the environment.

In 2025, Crédit Coopératif recorded an increase in the number of its clients, particularly individual customers (+3.7% excluding protected adults).This momentum is reflected in a significant increase in the number of its cooperative shareholders, both legal entities (+3.0%) and individual customers (+9.8%), as well as in the granting of loans (+5.7%) and fees and commissions (+6.6%).

The year was marked by the launch of its strategic plan entitled “100% committed”, a development plan aimed at strengthening its different banking model, serving societal and environmental transitions. Key metrics such as the share of green loans, the cooperative shareholder base, and the number and type of clients were established. The first targets of this plan have been achieved: such as the share of green loans for individual customers (6.3% for a target of 5%) and legal entities (15.8% for a target of 15%).

Crédit Coopératif is also preparing the acquisition of Anytime from Orange Bank to enhance its digital offering for associations. Private impact banking and impact investment banking were launched, responding to a growing demand for banking services that combine financial performance and social utility. Finally, the legal bank Avenir Crédit Coopératif was created to safeguard the business of corporate clients.

Crédit Coopératif’s three business line subsidiaries recorded sustained activity:

• Ecofi, the listed asset management company of the Groupe Crédit Coopératif, maintained dynamic net inflows exceeding €1 billion for the second consecutive year, demonstrating the confidence of investors. The historic monetary mutual fund (SICAV), Ecofi Trésorerie, has exceeded the €6 billion threshold in outstandings, consolidating its position in the market. In addition, Ecofi Smart Transition, a mutual fund of European equities aligned with the Paris Agreement, crossed the €250 million threshold, representing inflows of around €200 million in just a few months, illustrating clients’ interest in the search of meaning and Ecofi’s commitment to sustainable finance.
• ESFIN Gestion, an asset management company subsidiary of Crédit Coopératif that manages more than €300 million, saw strong growth in its fundraising activity on behalf of third parties, with four rounds in progress, including the InvESS Ile de France Développement Fund, dedicated to the SSE and impact. Disposals also reached a historic amount of more than €47 million, demonstrating ESFIN Gestion’s ability to deliver returns and liquidity for its subscribers. By strengthening its partnership with Banque des Territoires and France 2030, ESFIN Gestion has supported more than 60 structures with equity, for an amount deployed of more than €27 million, illustrating ESFIN Gestion’s commitment in the sector.
• Lastly, BTP Banque, which finances SMEs and mid-sized companies in the Building and Public Works sector, enjoyed dynamic conquest with the acquisition of more than 1,000 new clients, in a context of a declining market. The bank made more than €1 billion in guarantees on the markets, with 20% of its medium-term loans labelled “green”. The launch of the legal bank, Avenir BTP Banque, also marks an important step in preserving the business of clients.

Caisses d’Epargne

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

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

At the service of local economic, social and environmental development

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

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

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

• 100% useful to economic development: as banks serving all their customers and their territory, but also as local businesses and major employers in the region;
• 100% useful to the environmental transition: by building solutions to enable everyone to become a player in this transition, and by financing projects that will help accelerate it in local areas;
• 100% useful to social progress: as cooperative banks, having always been committed to the principles of solidarity and the fight against exclusion.

Individual customers

The Caisses d’Epargne business was strong in 2025 on the retail market.

In home loans, production was boosted by a market recovery in 2025 and amounts to €24.4 billion. The household market share of home loans stood at 14.06% in the third quarter of 2025. The Caisses d’Epargne have deployed several innovative solutions, in particular the impact home loan, for which outstandings already amount to €2 billion. Caisse d’Epargne is also continuing to support household housing and energy renovation through its dedicated offers and services and partnerships with players and professionals in the sector, including Cozynergy, Leroy Merlin and Vérisure.

In terms of inflows, the household market share stood at 9.24% in the third quarter of 2025. It remained at 13.93% on bank savings. The life insurance business was particularly buoyant, with gross inflows reaching €14 billion on a cumulative basis and generating an overall surplus of €4.7 billion. This activity was boosted by the marketing of Natixis loans, support for clients through retirement and the launch of innovative offers such as VEGActive Protégée, which combines the advantages of a structured fund with those of active management.

The Caisses d’Epargne developed their clients’ insurance equipment thanks to the development of a global strategy on protection, property insurance, personal risk insurance and remote monitoring, etc.

In the end, the Caisses d’Epargne maintained their strong growth in client satisfaction in the retail market with an NPS of 26, i.e. +2 points compared to 2024 (data at November 2025).

Supporting young people and families has been a common thread in the strategy of the retail market, with a strong challenge to win new clients and provide access to banking services. New everyday banking services are being launched for single parents and young people. Caisse d’Epargne thus reaffirmed its presence with young people by launching the Ados (teens) app, which includes services adapted to their needs, particularly in terms of secure management of their cards and also advice and tutorials to familiarize them with how to manage their budget.

The year was marked by the launch of the innovative savings solution VEGActive Protégée, designed by VEGA Investment Solutions, a management company affiliated with Natixis Investment Managers. Thanks to this mutual fund, savers benefit from active management on the international markets and protection, at maturity, of 90% of the initial capital.

Finally, the Cooperative shareholders’ Club, a new community space, gives the 4.4 million cooperative shareholders the opportunity to make their voices heard, support useful projects, have a positive impact and act locally within a community united by cooperative values.

Protected persons

The Caisses d’Epargne remain the leading bank for protected persons, persons under guardianship, trusteeship and dependent adults living at home in France. On the ground, over 220 specialized advisors are on-hand to assist family representatives and legal guardians.

Between 2009 and 2024, the share of protective measures opened, by age population, increased sharply for young adults and those over 60 years old. Family authority has replaced certain guardianship measures, but it has also made it possible to meet an unmet need by simplifying the procedures to be carried out. The number of beneficiaries of family authority is estimated at around 105,000 people at the end of 2025.

Corporate clients

With 40,509 clients (VSEs, SMEs and mid-sized companies), the Caisses d’Epargne continued their commitment to business development in 2025.

Through its utility contract, Caisse d’Epargne supports its corporate clients in adapting their activities to climate change and confirms the acceleration of its support for decarbonization through deployment of the ESG strategic dialog, increase in the production of sustainable financing, the range of Impact Loans dedicated to SMEs and mid-sized companies as well as the collaboration of renewable energy expertise and Natixis CIB’s Green & Sustainable Hub. In tangible terms, Caisse d’Epargne encourages companies to incorporate more non-financial criteria into their business models and offers a complete range of solutions to highlight their ESG approaches to stakeholders.

In particular, through systems dedicated to e-invoicing, it supported its clients in their implementation of regulatory compliance, which will become mandatory for all companies subject to VAT in France, between July 1, 2024 and January 1, 2026. Cybersecurity remains a priority because it is no longer a question of knowing “IF” a company is at risk of malicious cyber acts, but “WHEN” it will occur. In response to these challenges, Caisse d’Epargne has structured its offers and strengthened its awareness-raising process around these crucial themes.

Concerning the agricultural sector, the member cooperatives of the UFG (Union Finances Grains), a union of 34 cooperatives whose objective is to facilitate the provision of funds to finance their cereal stocks, were supported through the establishment of the NeuCP (Negotiable European Commercial Paper) Program. This issue of short-term negotiable securities represented a credit line of around €139 million for the Caisse d’Epargne network.

Caisse d’Epargne also confirmed its position as banker for industries, with an average penetration of 20%, including non-energy and energy.

Lastly, through its Néo Business program, the Caisses d’Epargne supported the development of innovative companies throughout France and in all business sectors. Today, 1,850 start-ups / scale-ups are supported in their growth with dedicated solutions, including 6 of the 26 French unicorns, 28 from the new French Tech 120 class in 2025.

Institutions

The regional public sector and social housing contracts are very heavily dedicated to the financing of regional equipment: networks, development, public infrastructure and housing. They are therefore in the first line for transition investments.

Regarding social housing, the target is to build 100,000 new social housing units per year while demand is exploding: at the end of June 2025, around 2.87 million households were waiting for social housing. In this context, the Caisses d’Epargne, along with Habitat en Région, confirm their long-standing commitment to social housing players, both in the traditional social component and in intermediate housing, with €2.1 billion in commitments in 2025.

They also remain the leading private banks for local authorities, with €2.9 billion in new financing loans in production over 2025; they are also present in the semi-public sector in development and services, with €691 million in new MLT loans and €2.4 billion in outstanding MLT loans.

At end-December 2025, outstanding deposits excluding DAV (LS and SEMAS) amounted to €7.4 billion, down 3%. In 2025, three EIB envelopes remain in the process of being marketed: Water and Sanitation, Energy Efficiency and Sustainable Mobility, and Renovation or Extension of Existing Sports Facilities. This last package, which expired at the beginning of August 2024, has been extended by one year, which has made it possible to accelerate its marketing.

For the public sector, in a tense context, medium and long-term commitments are up compared to 2024 but differ structurally. Production via the CE balance sheet increased to represent 47% of the total. Compagnie de Financement Foncier (SCF)’s share of 53% of production was down compared to 2024 (73% in 2024). The SCF activity was affected by a decrease in the competitiveness of the internal transfer rate compared to the competition in the first eight months of the year, which resulted in the loss of a number of significant calls for tenders.

Finally, on the professional real estate market, after two years of crisis, the new property market is showing signs of stabilization; credit rates fell slightly and the PTZ (zero-interest loan), extended until 2027, supports home ownership. However, construction costs and environmental standards keep prices high. New home sales remained down (-10% year-on-year) and the stock to be sold reached nearly 22 months, an historically high level. In this context, new MLT loans amounted to €1.3 billion, i.e. 92% of the target. In the short-term, production, although down, remains relatively solid at €1.9 billion (excluding renewals), or 91% of the target. The continued increase in the production of impact loans, which doubled between 2024 and 2025 to reach €92 million can be noted.

Communication

2025 was a year rich in communication actions for Caisse d’Epargne, which reaffirmed its positioning as a bank for families while committing itself to young people, professionals and businesses.

In the media, a campaign was rolled out to promote the “family formula”, and in particular the option dedicated to single-parent families, demonstrating the brand’s commitment to all families. Another highlight of the year was the launch of a Cooperative shareholders’ Club offering exclusive benefits: a campaign that strengthened its image as a cooperative bank and a bank of utility among its cooperative shareholders.

The brand, which has long been very involved with young people, has also launched innovative initiatives, such as the live show “Réponse Cash” on Twitch, an educational game on money matters. It also has an educational TikTok account that already has more than 60,000 subscribers, making the Caisse d’Epargne one of the most followed bank accounts on this network.

On the corporate side, a targeted four-month press and digital campaign highlighted the brand’s expertise, supplemented by a radio campaign on e-invoicing, illustrating its support for professionals.

Caisse d’Epargne also pursued its commitments, notably by rolling out a campaign to mark the 60^th anniversary of the law on the financial independence of women. This commitment is also reflected in numerous sponsorship initiatives. The brand renewed its partnership with the French Handball Federation for four years and announced that it has renovated more than 120 sports fields across the country as part of the Pacte Utile. This year ended on a high note with the bronze medal won by the French team at the Women’s Handball World Championships.

Lastly, Caisse d’Epargne received several professional awards, including an Effie award, in recognition of the performance of its communication initiatives.

Banque Palatine

Banque Palatine, a 100% subsidiary of BPCE, is mainly dedicated to mid-sized companies, executives and private banking. For more than 240 years, Banque Palatine has been working alongside entrepreneurs on both a professional and personal level. It provides them with a range of banking products (current accounts, real estate and personal loans, financial investments, financing solutions to meet environmental challenges) and insurance products. Its network is made up of 38 sites, including 26 business centers and private banking and four Premium branches offering all remote banking services.

Banque Palatine offers value-added expertise dedicated to supporting its customers’ growth and performance: wealth, legal and tax engineering, investment advice, global approach to managers’ assets, corporate finance, specialized approach to real estate, trade finance, customer desk, etc.

In the regulated real estate market, where the Bank is the market leader, and in the audiovisual market, where it is a key player, it deploys a dedicated national organization.

Its signature “The art of being a banker” illustrates Banque Palatine’s determination to develop a model of close relationships based on excellent support for its 13,000 corporate and 45,000 private clients.

The corporate market had a particularly dynamic year in 2025, in synergy with the network of business centers, investment bankers, large corporates and institutions, specialized financing, the creative and audiovisual industries division, and the regulated real estate professions. The drive to win over companies with revenues exceeding €15 million continued, with 288 new clients active in this segment. The “corporate” teams also helped win over 304 new private banking, executives and senior managers among its corporate clients.

Despite an economic situation calling for the revision of corporate investment plans, the financing activity remained dynamic and the corporate finance activity was strong with an annual fee and commission performance of €14.1 million. The network of business centers and the specialized business lines recorded new loans to companies of €2.8 billion in 2025, including €0.7 billion in structured financing. 29% of the financing granted is “green”.

In Private Banking, client acquisition remained at a good level, with the 1,000 new client mark reached in early October 2025. Inflows in financial savings, equipment of clients with savings products, the performance of wealth audits and life insurance inflows also showed a very good trend.

Two major events marked the year in 2025:

• Banque Palatine rolled out its Sustainable Finance system, aimed at stepping up support for its clients in the environmental transition. The year was marked by numerous launches: implementation of the SAMI, Naldéo, Opéra Energie, EDE and Cozynergy group partnerships; launch of the impact real estate loan for private clients; launch of the first green EMTN, Palatine GreenCap 2032; extension of the impact financing offer for companies, etc. Banque Palatine published its first sustainability report and was awarded the CSR Committed labels at the confirmed and Cancer@Work stage. Finally, through sponsorship, it supports a mangrove planting project in Madagascar in order to sustainably restore this ecosystem, which is essential for biodiversity, the climate and local communities.
• Next, the audiovisual media division was transformed to become the hub for the creative and audiovisual industries, thus opening up its strategy of conquest in the cultural field beyond the cinema and audiovisual sector, where Banque Palatine is now one of the leading banks in France.

Insurance division

As a fully-fledged insurer, Groupe BPCE designs, distributes and manages a comprehensive range of personal and non-life insurance products for clients of its banking networks through BPCE Assurances¹, as well as sureties and financial guarantees through Compagnie Européenne de Garanties et Cautions (CEGC).

Its subsidiaries are BPCE Assurances IARD, BPCE IARD, BPCE Vie, BPCE Life.

In 2025, the personal insurance business was dynamic and helped to consolidate our ambition to become the 4^th largest insurer in France by 2030. Gross inflows reached €16.3 billion in savings at the end of December 2025, up 7% compared to the previous year. The year was also marked by the launch of numerous offers and changes to paths to better meet the needs of policyholders: marketing of the Climate Future Savings Plan (PEAC), which Groupe BPCE is the first major French player to have launched, implementation of the self-care subscription of the Individual Retirement Savings Plan, and opening of the offer of BPCE Life, a company incorporated under Luxembourg law in the Insurance division, to Banque Palatine clients.

In payment protection insurance (ADE), after a difficult year in 2024, contract production was up steadily during the year in a context of a recovery in new home loans. In 2025, the ADE offer has evolved twice. First, BPCE Vie and CNP Assurances launched and generalized marketing of the new ADE offer for professionals and corporates with all Banques Populaires and Caisses d’Epargne. Then, the end of exclusions for people in remission from male cancer was announced.

In 2025, the non-life insurance (IARD) business was marked by the increase in the premium allocated to the financing of the natural disaster plan. According to France Assureurs, by the end of September 2025, the revenues of the Property & Casualty Insurance market was up by nearly 8%.

At the same time, difficulties in the automotive sector and the decline in registrations are intensifying competition. The recovery in home loans, although still limited, is on the other hand a more positive element.

Despite the unfavorable dynamics for bancassurers, BPCE’s non-life insurance (IARD) business line proved to be resilient, with a portfolio for individual clients up by 1% (at end-September 2025 compared with end-September 2024), and by 6% for professionals. Several highlights marked the year including: the launch of impact home insurance, to encourage and reward policyholders’ eco-responsible commitment to environmental challenges; production launch of a first use case based on the use of generative AI, to accelerate the processing of client complaints; a pilot with the company FlowStop to offer clients cofferdams at special pricing. Lastly, BPCE Assurances IARD was awarded the “Great Place to Work for Women” label, reflecting its commitment to building a respectful, inclusive and caring work environment.

In 2025, the need for sureties and financial guarantees was sustained. Compagnie Européenne de Garanties et Cautions (CEGC) guaranteed 197,167 home loans for individual clients, produced by Groupe BPCE networks, for a total of €27.4 billion, up 32% compared to 2024 and in line with market growth1 of 35%. In the construction sectors, CEGC covered the delivery “at the agreed price and deadline” of 9,358 single-family houses and issued financial guarantees for the completion of 614 real estate development projects. Finally, in the building, construction, company and industry sectors, 120,116 market guarantees were issued, mainly via the www.cautiondemarche.com solution, which is particularly popular, with a “Net promoter score” of +62².

In an economic environment that is not very favorable to real estate, CEGC’s role takes on its full meaning. Its robust risk profile enables it to meet its commitments and facilitate the implementation of its clients’ projects. Its proven expertise in risk assessment and very good knowledge of the real estate ecosystem make it possible to support professionals in the sector and accompany the recovery.

The year was marked by the deployment of the Subcontractor Payment Guarantee (GPST), which enables its single-family home builder clients to build trust with their subcontractors and meet regulatory requirements. DBRS and Moody’s renewed CEGC’s ratings, A High and A1, respectively, demonstrating the quality of its credit rating and its robust credit profile. Finally, CEGC obtained a score of 80/100 in the EcoVadis assessment, which places it in the top 2 French companies, all sectors combined.

• 1 Banque de France. Published on January 9, 2026. Change in new home loans excluding renegotiations, first 11 months of 2025 compared to the first 11 months of 2024.
• 2 Source: CEGC listening runs carried out by the Enov institute, cumulative 4 quarterly waves carried out in 2025, with 295 corporate market guarantee end clients. Telephone-administered quantitative questionnaire.

The Digital & Payments division

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

Oney is a different, unique bank born from a commercial background. A partner in the transformation of retail for over 40 years, Oney designs solutions for payment, consumer financing, insurance and anti-fraud solutions. Creator of split payment in 2008, Oney is the leader in the BNPL (Buy Now Pay Later) market in France. A strategic ally of more than 37,000 retailers, Oney supports the purchasing and project completion of nearly 7 million clients in Europe by offering them quick and simple digital shopping experiences. Every day, its 1,900 talents in 10 countries drive the ambition to be a more human and responsible bank, a major player in Europe in retail consumer finance. With the support of its two shareholders, BPCE (50.1%) and ELO (formerly Auchan Holding at 49.9%), Oney brings together the best of banking and commerce. Within Groupe BPCE, Oney operates within BPCE Digital & Payments, a division bringing together payment, digital and data expertise.

BPCE Payment Services, with its recognized expertise in the field of electronic payment processing and payment flows, supports Groupe BPCE’s banks and subsidiaries as well as external customers consisting of financial institutions and payment service providers. The subsidiary now manages more than 30 million payment cards, 11 billion transactions per year, and more than 500,000 merchant contracts for their needs in payment terminals and associated services. Its pioneering culture in terms of innovation has enabled the Group’s institutions to position themselves as pioneers in a number of payment market standards, such as Apple Pay, instant transfers and more recently, Tap to Pay.

Payplug, an omnichannel payment solution, is a specialist in payment cards and payment acceptance and acquisition services. This fintech is aimed at retailers and e-merchants of all sizes for whom the European market and its various local payment methods represent a priority issue.

Xpollens, Groupe BPCE’s Banking as a Service platform, optimizes all incoming and outgoing payment flows and offers payment methods, IBANs and virtual accounts that can be integrated via API without changing banks.

In addition, the division has three departments:

• The Digital client department, composed of digital experts who design remote banking for the Group’s institutions, and ensure its continuous improvement by developing the best applications thanks to AI and Data.
• The AI & Data department designs and deploys services and tools that exploit the potential of data, for the benefit of the competitiveness of each of the Group’s business lines. By placing artificial intelligence at the service of performance and simplicity, they enrich the client experience, optimize processes for advisors, and facilitate the daily lives of all Group employees.
• The Innovation department whose mission is to build new sources of revenue, incubate internal and external strategic projects and participate in the capital of technology companies. Its work focuses on open finance, blockchain, new payment methods and the energy transition.

The Financial Solutions & Expertise division

The Financial Solutions & Expertise (FSE) division brings together, within BPCE, expertise in financing, services and advice, for the Group’s corporate clients.

The entities that make up FSE are:

For the financing business lines

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

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

BPCE Equipment Solutions is a major player in the financing of equipment leasing internationally. Created in March 2025, this subsidiary is the result of the acquisition of Société Générale Equipment Finance (SGEF).

BPCE Factor develops factoring solutions for companies of all sizes, at any stage of their growth process (creation, development, external growth, international development, etc.).

SOCFIM specializes in financing real estate professionals (developers and investors). Its activity covers the whole of France and all asset classes: new and existing housing, managed housing (students and seniors), offices, retail and logistics warehouses.

For the custodial and advisory business lines

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

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

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

1.4.2 Global business lines

Corporate & Investment Banking

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

Natixis CIB is organized around six main business lines (Global Markets, Investment Banking, Real Assets, Global Trade, M&A, Credit Portfolio & Resources Management):

• The Global Markets business line offers a wide range of hedging, financing and investment solutions on the fixed-income, credit, foreign exchange, commodities and equity markets, combined with recognized economic research.
• The Investment Banking teams support their clients in their strategic decisions: acquisitions, asset sales or purchases and, more generally, any growth project. Offering high value-added solutions, Investment Banking encompasses strategic and acquisition financing, financing on the primary bond and equity markets, and financial engineering for listed holdings.
• The Real Assets business line combines the origination and structuring of structured finance in the sectors of aviation, infrastructure & natural resources and real estate & hospitality. Real Assets is recognized as one of the market’s major players in these sectors.
• The Global Trade business line includes the international trade financing activities, structured financing solutions for export transactions and cash management for its corporate clients, commodity traders and for customers of the Banques Populaire and Caisse d’Epargne networks. This business line, at the heart of the Group’s strategy, aims to support and finance the commercial development of its clients in a sustainable manner.
• The Portfolio management teams (CPRM) intervene in support of all financing activities. They are at the heart of the Originate-to-Distribute (O2D) model and ensure the strategic optimization and allocation of resources.
• Finally, the teams specialized in mergers and acquisitions (M&A) support large- and medium-sized commercial and industrial companies, institutional investors and investment funds in the preparation and implementation of divestments, mergers, fundraising, restructuring or capital protection. This expertise is based on a network of nine boutiques in nine countries: Natixis Partners, Solomon Partners, Fenchurch, Natixis Partners Iberia, Natixis Partners Belgium, Emendo Capital, Vermilion, Azure Capital and Clipperton.

Around these major business lines, the Advisory & Coverage division dedicated to client coverage, brings together bankers, sector experts and teams in charge of supporting its clients’ environmental and technological transitions. To ensure a close relationship with clients , this division has a strong regional presence in France, and draws on all the bank’s teams of experts abroad.

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

• 1 IFR Awards 2025
• 2 Euromoney
• 3 IJ Global – EMEA 2025
• 4 Expertise on nine key sectors: Energy security and decarbonization; Low-carbon energy; Critical Metals & Minerals; Food, agriculture & natural capital; Health; Telecom & Tech; Mobility; Environment; Residential
• 5 IJ Global
• 6 Deal Catalyst US CLO Awards 2025

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

One of the world’s leading asset managers with €1,323 billion in assets under management at December 31, 2025, Natixis Investment Managers (Natixis IM) supports investors on every continent in building their portfolios, offering them a wide range of diversified, responsible solutions.

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

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

• – conviction management (fundamental active),

• – management under liability constraints (insurance and retirement/pensions),

• – private assets.

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

Employee and pensions savings

Natixis Interépargne, France’s leader in responsible corporate savings, is the trusted partner of over 115,000 companies¹ of all sizes, helping them set up and manage their employee and pension savings schemes, serving nearly 4 million French savers¹.

Drawing on the wealth and diversity of Natixis Investment Managers’ best expertise, it provides its clients with a high-performance and sustainable management offering that is among the most recognized on the market², with more than €44 billion in assets under management¹.

Fully committed to its societal role, Natixis Interépargne supports the development of useful savings, in the belief that value sharing is the best solution to align the interests of shareholders, managers and their employees, to serve the company’s performance.

• 1 Source: Natixis Interépargne at June 30, 2025
• 2 Since 2015, Natixis Interépargne has been regularly recognized by the Corbeilles Mieux Vivre Votre Argent

Wealth management

Established in France and Luxembourg, Natixis Wealth Management designs and implements tailor-made wealth management and financial solutions to structure and manage the assets of business leaders, senior executives, large private investors and holders of a family capital.

It supports them in their initiatives to enterprise, invest and transmit, and mobilizes a wide range of expertise that covers all their needs, whatever the size or maturity of their projects: corporate advisory, origination, vanilla and complex financing, investment, portfolio engineering, asset management and diversification solutions, particularly in private equity. The entire value proposition is tailored to the degree of personalization desired by the customers and is distributed via two channels: BtoC and BtoB. To expand its range of listed and unlisted asset management products and services, Natixis Wealth Management draws on the complementary expertise of its four subsidiaries: Massena Partners, dedicated to advising private family groups and family offices, mainly in private equity; Dorval Asset Management, expert in flexible and responsible asset management; Teora by Natixis Wealth Management, specializing in high-end life insurance brokerage in open architecture; as well as VEGA Investment Solutions.

• 1 Source: Natixis Interépargne at December 31, 2025.

https://groupebpce.com/

“Investor Relations” section

François COURTOIS,

Director of Financial and Non-Financial Communication, Investor Relations, ST Credit Facility Sales and Rating agencies.

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.

Part 1 General information

1.1 Basis for preparation

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

Groupe BPCE has established its sustainability report in accordance with the European Sustainability Reporting Standards (ESRS), as mandated by Article 29b of Directive 2013/34 of the European Parliament and of the Council from December 14, 2022. 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, clients, 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 (IROs) 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 Groupe BPCE’s IFRS (International Financial Reporting Standards) scope of consolidation 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:

Certain subsidiaries included in Groupe BPCE’s scope of consolidation are exempt from the obligation to provide individual and consolidated sustainability disclosures. This is partly due to the fact that they do not issue securities on a regulated EU market:

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.

Nor has Groupe BPCE made use of the exemption from reporting disclosures on imminent developments or deals under negotiation, in accordance with Articles 19a(3) and 29a(3) of Directive 2013/34/EU.

1.1.2 (BP-2) Disclosures in relation to specific circumstances

1.1.2.1 Time horizons

Material impacts, risks and opportunities have been assessed in the short, medium and long term, or using a constant timeframe (when materiality remains identical across short, medium, and long term periods). The forward-looking information in Groupe BPCE’s sustainability statements relies on the general principles outlined in Section 6.4 of ESRS 1 Definition of the terms “short-”, “medium-”, and “long-term” horizons for reporting purposes:

• 1 year is defined as “short term” (period covered by the annual financial statement);
• Between 1 year and 5 years is defined as “medium term”;
• More than 5 years is defined as “long term”.

When the time horizons deviate from these general guidelines, this information is indicated 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 estimations

The indicators must cover the entire scope of consolidation. 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 to financed emissions.

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

• Data purchased from suppliers (Carbone4, Trucost, CDP, MSCI);
• 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 PCAF¹.

• 1 Partnership for Carbon Accounting Financials (PCAF) methodology.

1.1.2.3 Sources of uncertainty regarding estimations and outcomes

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”). During this second year of application, the absence of sectoral standards specific to banking and insurance activities remained, generating uncertainties on the methodological approaches to be used and the availability of data, particularly those relating to 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 report, 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 asses 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 Part 1.5.2 List of material IROs, we considered that for the Environment (E) topic, only the issue of climate change mitigation and adaptation is material within the meaning of the standard. Limitations on the amount of information available at this stage prevented the group from assessing the materiality of the ESRS Nature topics as defined by the standard, leading it to evaluate these environment-related issues as non-material. This assessment was 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 assessment may change in the coming years. 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 risk factors presented in the chapter on risk management.

For the data points presented in this report, Groupe BPCE 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, analyses, 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: Groupe BPCE 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) - i,e., general standards - that 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.

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 clients. The actions described present, in particular, the achievements and roadmap for the initiatives that seem to produce an impact via the downstream value chain. The group’s transition plan accordingly describes its past, current and future efforts to align its financing, investment and insurance portfolios with scientifically established trajectories toward global carbon neutrality in 2050, there by supporting its clients in 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 clients, companies or States that it supports in their 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 (GHG) 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 clients 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 CO₂e emissions of its financed clients or securities in which it invests. This calculation takes into account clients’ scopes 1, 2 and 3, which therefore also include emissions from their value chain, and leads to a maximalist calculation. It is estimated that the emissions financed 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 report, the group considered the mandatory material 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 section 2.2.7.1 (E1-6) Gross Scopes 1, 2 and 3 and Total GHG emissions.

Regarding Taxonomy, the assumptions used and limitations imposed 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 lie beyond the control of Groupe BPCE, are 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

No material 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

No material errors related to the prior period have been 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 risk management in the Universal Registration Document.

In addition, the elements relating to the eligibility and alignment of the group’s portfolios 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 of information 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.

Where the topics covered by the ESRS have material consequences for the consolidated financial statements, information is provided in the notes. In particular, Notes 2.3 “Use of estimates and judgments” and 7.1.2 “Change in gross carrying amounts and expected credit losses on financial assets and commitments” describe how credit and environmental risks are taken into account in the financial statements.

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

1.2 Cooperative dimension

Groupe BPCE is a cooperative full-service bank and insurance group serving its clients, cooperative shareholders, territories and the economy. Its territorial model is inseparable from the history of its two longstanding retail banking networks, Banque Populaire and Caisse d’Epargne. These roots, which define the group’s identity, also condition its financial and non-financiel performance.

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.

Strong and proud of its many facets, 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.

Thanks to its unlisted cooperative status, which enables it to invest to meet the challenges of the futur, the group’s action is geared to the long term and provides local and concrete responses to the transformations of the economy and society at large. Its sustainable business 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 9.6 million cooperative shareholders.

Cooperative shareownership, 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 9.6 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 ( via local savings companies, 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, closely connected to 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 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 serving the vitality of territories. 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 funding circuits. Local savings and results finance projects at local level, purchases are promoted from local suppliers, and the group creates jobs as close as possible to the local and regional level;
• By promoting local ecosystems and dialogue with its stakeholders such as chambers of commerce and industry, professional associations, players in the social and solidarity-based economy, entrepreneurial ecosystems, educational structures, associations, foundations, mutual organizations. Recognizing that addressing social and environmental issues calls for united action, the group stands alongside all those who join forces to take action.

Cooperative performance to ensure long-term growth: VISION 2030

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 guided by a financial and non-financial “cooperative performance” model and embraces a long-term perspective that reconciles robustness, subsidiarity, and impact.

Robustness

The group’s status as an unlisted company protects it against all forms of speculation; its reserves are indivisible and the value it creates 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 being devoted to regional development.

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 maintains some of the highest solvency requirements.

Subsidiarity

Groupe BPCE’s decentralization and regional presence are real assets for supporting transitions and the lasting transformation of society; they ensure that decisions are made rapidly and as close as possible to the regions concerned.

Impact

With its VISION 2030 strategic project, the group aims to “make impact accessible to all”: this is the positive impact¹ for all whose general implementation is based on three main principles:

• 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 as a whole: 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 all directors: by deploying an Impact Inside operation and by mobilizing 100% of Groupe BPCE’s employees, companies and governing bodies around ESG challenges.

• 1 VISION 2030 strategic project terminology:https://www.groupebpce.com/en/the-group/strategic-plan/

1.3 Strategy

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 clients and their support in the face of the challenges of environmental, demographic, technological and geopolitical transitions.

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

In this way, both environmental and societal sustainability lies at the very heart of the group’s strategy.

A group with “positive impact”¹

VISION 2030 outlines the main priorities that Groupe BPCE has set itself in order to build a growth project at the service of its clients.

Groupe BPCE is mobilizing its local and regional presence, its business lines and expertise, to enable its clients, cooperative shareholders and employees to reassert their agency and trust in their future.

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 “impact accessible to all”2 means raising awareness and massively supporting all its clients in the environmental transition through expertise, ranges of advisory services and the provision of global solutions.

By drawing on science-defined scenarios, Groupe BPCE and its business lines are positioning themselves as facilitators of transition efforts. The group’s approach is based on its cooperative business model, which combines a strong presence in local communities with societal engagement geared to financing the real economy. The measures implemented focus on the following areas:

• Impact solutions:

• – For individual clients: supporting energy renovation and the adaptation of housing to the advancing years of residents and their loss of autonomy by offering financing solutions and by mobilizing the group’s role as a housing operator and trusted third party, along with its network of partnerships,

• – For BtoB clients: supporting the transition of its clients’ business models ranging from SMEs to the largest international companies, and offering sustainable solutions for investor customers with a range of responsible investments,

• Support for the evolution of the energy mix, particularly in the development of renewable and low-carbon energies,
• Support for the evolution of the energy mix, particularly in the development of renewable and low-carbon energies;
• Alignment of its financing and insurance portfolios with trajectories based on scientific scenarios compatible with the objectives of the Paris Agreement³;
• Decarbonization trajectories offered by European asset management companies to their investor customers;
• Innovative approach in sustainable finance, by being an active issuer, with the aim of carrying out more than five issues of green, social or health financing 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 dynamics of the regions, notably by financing the construction or renovation of infrastructure and equipment necessary for education, health and mobility. They are the leading private financier of local authorities and the hospital sector;⁴

• – Globally, Natixis Investment Managers and Natixis Corporate & Investment Banking are developing their Asset & Wealth Management and Corporate & Investment Banking business lines in more than 40 countries in compliance with international commitments, in terms of investment and financing.

• Committed to supporting local and national initiatives:

• – the impact of the sponsorship of the 14 Banques Populaires is measured every year via their Cooperative and Societal Footprint. 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

To extend its impact solutions to its clients and accelerate each aspect of ESG, Groupe BPCE has undertaken a transformation of all its companies at all level, “Impact Inside”. On the one hand, it mobilizes its governance and its employees, whom it trains in ESG issues. On the other hand, it is also taking action on its own activities by reducing its carbon footprint.

• 1 VISION 2030 strategic project: https://www.groupebpce.com/en/the-group/strategic-plan/
• 2 VISION 2030 strategic project terminology: https://www.groupebpce.com/en/the-group/strategic-plan/
• 3 The objectives of the Paris Agreement are to limit global warming to +2°C, and if possible to +1.5°C, by 2100 compared to pre-industrial levels.
• 4 Observatoire Finance Active “Établissements publics de santé” (published in March 2025).

1.3.1.2 Sustainability-related targets

This strategy is accompanied by quantified objectives to implement and steer the group’s concrete through 2026.

A group mobilized to decarbonate the economy

• 1 Scope: Banque Populaire and Caisse d’Epargne networks. Annual production.
• 2 Scope: Banque Populaire and Caisse d’Epargne networks. Cumulative number of unique visitors since the launch in 2023 of the Sustainable Advice and Solutions module.
• 3 Scope: Banque Populaire and Caisse d’Epargne networks. Annual production of financing for SMEs and mid-sized companies for transition and decarbonization (in the form of green loans, impact loans, rolling equipment leasing (CBM), green lease with option to buy/long-term leasing (LOA/LDD)) + financing of renewable energy projects in the regions. Pro forma figure for 2024 (including data on production of renewable energy financing for 2024 in the regions).
• 4 Scope: Banque Populaire and Caisse d’Epargne networks. As a % of active corporate clients’ outstandings (on and off balance sheet).
• 5 Scope: Banque Populaire and Caisse d’Epargne networks, Energeco and Natixis CIB; Cumulative annual production over the 2024 - 2025 period compared to cumulative production over the 2021 - 2023 period.
• 6 Scope: BPCE Assurances. all corporate debt securities and shares held directly or through dedicated funds (Euro funds or similar). Reduction measured on the Scope 1 and 2 carbon emissions of portfolio companies.
• 7 Scope: Natixis IM. Assets under Management: sustainable bonds (Green Social Sustainability Bonds), impact funds and private assets classified under Article 8 and 9 SFDR.
• 8 Scope: Natixis CIB (sustainable finance, renewable franchises & new energies, activities with clients/Dark & Medium Green colored assets according to the Green Weighting Factor). Average annual growth rate of “Green” income (2023-2026), with a target set at 1.5 times the average annual growth of Natixis CIB’s total income over the same period.
• 9 Number of projects in line with the Ecosystem Services Method impact framework and validated by the Scientific Committee.

A group with a positive societal impact

Impact inside

1.3.1.3 Business model

Groupe BPCE’s cooperative dimension is the bedrock of its business model.

As part of its strategic development, Groupe BPCE mobilizes various assets (or resources) to create value for its various stakeholders both internal (employees) or external (clients, regions, civil society, investors, etc.) :

• – Its human capital, made up of employees and cooperative shareholders,

• – Its well-established and complementary brands,

• – Relationship models offering the best of human and digital capabilities, enhanced by artificial intelligence (AI),

• – Its financial strength, with a high level of capital, significant liquidity reserves and a guarantee and solidarity system between the group’s institutions.

Groupe BPCE considers the intangible resources indicated to be essential, as defined by regulations⁶.

• 1 Scope: Banque Populaire and Caisse d’Epargne networks; Annual production. Target calculated in relation to the 2023 reference year.
• 2 Scope: Banque Populaire and Caisse d’Epargne networks; Number of professional projects financed through microcredits.
• 3 Scope: Banque Populaire (Adie, France Active) and Caisse d’Epargne (France Active, IMC - formerly Créa-SOL) networks.
• 4 The “Impact Fundamentals” training module was delivered in September 2025. It was rolled out at BPCE boundaries (SA+ entities) and the training rate was 51% at December 31, 2025. For the Banques Populaires and Caisses d’Epargne, the launch is scheduled for the first quarter of 2026. For Natixis CIB and Natixis IM, specific modules will be rolled out in the first quarter of 2026.
• 5 Excluding FSE (in the process of being defined).
• 6 Essential intangible resources are defined as those that are “devoid of the physical substance on which the company’s business model fundamentally depends and which constitute a source of value creation for the company” French Commercial Code Art. L 232-1, II-7° and L 22-10-35 amended by ord. 2023-1142

Our challenges

Our 3 strategic pillars

• 1) Forging our growth for the long term
• 2) Giving our clients trust in their future
• 3) Expressing our cooperative values in all territories

• * VISION 2030 strategic project terminology: https://www.groupebpce.com/en/the-group/strategic-plan/

Our business lines

Our value creation

• ⁽¹⁾ 21.19% market share in outstanding loans, all non-financial sector customers (Groupe BPCE, Banque de France Q3 2025).
• ⁽²⁾ Market share: 21.77% in household deposits/savings and 26.20% in home loans (Groupe BPCE, Banque de France Q3 2025). Overall penetration rate of 23.9% among retail clients (SOFIA Kantar study, 2025).
• ⁽³⁾ 2025 Kantar SME-SMI survey.
• ⁽⁴⁾ Observatoire Finance Active des Collectivités Locales (published in March 2025).
• ⁽⁵⁾ L’Argus de l’Assurance “Bancassurers’ Classification, 2025 edition”.
• ⁽⁶⁾ Investment & Pensions Europe Media (IPE) - Top 500 Asset Management 2025 Report – Natixis IM assets under management at 12/31/2025: €1,323 billion.
• ⁽⁷⁾ Population of adults under professional mandate estimated at more than 820,000 (source: Ministry of Justice) – Caisse d’Epargne network: nearly 356,000 protected customers at September 30, 2025.

1.3.1.4 Description of major product groups, markets and/or client groups targeted

As a universal, cooperative and regional bank, Groupe BPCE is a major player in retail banking and insurance in France, in specialized business lines in Europe, and in Corporate & Investment Banking and Asset Management activities internationally.

Groupe BPCE’s various business models, business lines and main markets/clients are detailed in section 1.4 The group’s business lines in chapter 1 Presentation of Groupe BPCE in the URD.

1.3.1.5 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 been gradually reinforced and 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 applicable to the oil and gas industry, 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.
• Defense and security: initially published in 2017, then updated in 2020, and covering the activities of Natixis CIB, the ESG policy applicable to the defense and security industry was extended in July 2025 to all Groupe BPCE’s banking activities and strengthened to reflect new sector-related issues.

Concerning Natixis CIB’s banking activities

• 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.

European asset management companies affiliated with Natixis Investment Managers 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 direct asset management companies ban controversial weapons from their investments, and have exclusion policies in the coal, non-conventional oil and gas, and tobacco sectors. The majority of asset management companies offering investment products in non-listed assets completely exclude fossil fuels in favor of transition and renewable energies.

As part of its investments, BPCE Assurances has implemented sectoral and normative ESG policies covering, in particular, the tobacco, defense and security, thermal coal, oil and gas, pesticides and palm oil sectors.

1.3.1.6 Commitments

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

Since 2021, Groupe BPCE has relied on the work of the Net Zero Banking Alliance (NZBA), an initiative of UNEP-FI that established a methodological framework for aligning banking books with the objectives of the Paris Agreement. This science-based methodological framework has already been used by more than 100 banks internationally, enabling unprecedented collective mobilization. This alliance has since modified its bylaws and no longer has any members, but retains the reference framework that it has build up. Thus, Groupe BPCE has published its positions on the eleven sectors of the economy with the highest carbon emissions (electricity production, oil and gas, automotive, steel, cement, aluminum, aviation, commercial real estate, residential real estate, maritime transport and agriculture).

Net Zero Asset Owner Alliance

BPCE Assurances (since 2022) and CEGC (since 2023) are members 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

Groupe BPCE strengthened 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 in 2024, the group 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.

1.3.1.7 Value chain

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

The upstream value chain includes suppliers of products or services.

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

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

Groupe BPCE value chain

Monitoring & Regulations

Financial, risk and compliance management

• Rating strategy (financial and non-financial)
• Portfolio management (assets)
• Balance sheet management (assets / liabilities)
• Risk management
• Compliance

Regulations

• Compliance with regulations
• Audit
• Regulator / supervisor communication

1.3.2 (SBM-2) Interests and views of stakeholders

Accounting for 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 frameworks 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 frameworks are detailed in the table below.

The group’s cooperative model places dialogue with stakeholders at the heart of its actions. The strong 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 dialogue 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 societes to which the group has given long-standing support, 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 strategy and more particularly, in the sustainable development of their bank. The members of the Board represent the cooperative shareholding customers, 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 (nongovernmental organizations). Lastly, discussions with regulators, and image or forward-looking surveys are all sources of identification of changes in stakeholder expectations.

Summary of stakeholder dialogue

Information on stakeholder consultation as part of the double materiality assessment is available in section 1.5.1.3 - Stakeholder consultation.

1.4 Governance

1.4.1 (GOV-1) Role of the administrative, management and supervisory bodies

1.4.1.1 Composition and diversity of BPCE’s management and supervisory bodies

Supervisory Board and Management Board

The Supervisory Board of Groupe BPCE has 19 members¹: 7 representatives of the Banques Populaires, 7 representatives of the Caisses d’Epargne, 3 independent members² and 2 employee representatives. The Supervisory Board includes six non-voting directors acting in an advisory capacity.

As of December 31, 2025, 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 members⁴, including a Chairman. The gender 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 Report on corporate governance in the Universal Registration Document.

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.

Expertise and skills of the Supervisory Board regarding sustainability

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 respective banks and have in-depth knowledge of the cooperative business model, their region and regional specificities.

The skills of the members are reported in the collective skills matrix of the Supervisory Board in Chapter 4 Report on corporate governance in the Universal Registration Document⁶. 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 each member’s terms of office sheet,⁷ which describes his or her experience in detail.

• 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 Report on corporate governance in the Universal Registration Document.
• 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 female 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 female members of the Management Board by 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 Refer to section 4.3.5 Directorships and offices held by corporate officers in Chapter 4 “Report on corporate governance” in the URD.

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: 3.82/5

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.

• 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 uses of socially beneficial nature, 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: 4.54/5

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 the banking and financial exclusion of all players in economic, social and environmental life. Knowledge of these specificities, the very essence of the group’s business model, is the basis of this “cooperative banking experience”.

• Regional specificities: 4.21/5

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

• Economic and regional environment: 4.41/5

This expertise covers knowledge of the strategies for the development, revitalization and optimization of a region as well as the ability to understand 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 account of 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 Report on corporate governance in the Universal Registration Document.

The training offered in 2025 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, the scientific context, climatic and environmental risks, the resulting challenges for the bank and the regulatory context and its implications for the bank;
• Sustainable finance updates: training with an external provider aimed at presenting sustainable finance regulations and their impacts for the group;
• Non-financial management - The sustainability report and the voluntary impact report (BP and CE): internal training aimed at reiterating the vision of the Impact of Groupe BPCE and its companies, presenting Groupe BPCE’s sustainability report, and specifying the relationship with the voluntary impact reports published by the Banques Populaires and Caisse d’Epargne institutions for their scopes;
• ESG risks and impact strategy: internal training aimed at updating the presentation on the sustainability report based on new information published as part of Groupe BPCE’s sustainability report.

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 provides perspective on,the group’s ESG strategy. 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 Report on corporate governance in the URD).

Supervisory Board

Supervises and gives perspective on Groupe BPCE’s ESG strategy

Executive Management Committee

Validates the ESG strategy, ensures its implementation and oversees risk management

Implementation

Internal stakeholders co-construct the group’s ESG strategy with the Impact department and ensure its implementation within their scope

The 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 required by the company’s interests and legal and regulatory provisions. 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, regulated 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 on November 27, 2025 and to the Audit and Investment Committee on December 9, 2025. These two committees communicated their report at the Supervisory Board meeting held on February 3, 2026.

The material impacts, risks and opportunities (IROs) focus on: climate change, own workers, affected communities, consumers and end-users and business conduct. The skills¹ of the members of the management and supervisory bodies in connection with these IROs are available in Chapter 4 Report on corporate governance in the Universal Registration Document.

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 metrics 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).

The sustainability strategy outlined in the VISION 2030 project covers the impacts, risks and opportunities identified on environmental and societal issues. The strategic ambitions for 2026 are broken down into action plans, piloted within the program framework. These programs, under the direct responsibility of a member of Executive Management Committee or the Executive Committee, are presented quarterly to the Executive Management Committee.

An “Impact Inside” approach managed by the Impact divison

The Impact department, 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 ensures the smooth operational execution of projects to implement the ambitions of the Impact VISION 2030 on the Environmental, Social and Governance (ESG) dimensions, ensuring overall coordination and support for each function.

The Executive Management Committee oversees projects related to the implementation of the Impact VISION 2030 for the group, with a regular review of the portfolio of structuring projects;

The Environmental Transition Strategy Committee validates the main operational guidelines and monitors the deployment of environmental projects;

An Impact Committee, bringing together ten executives from the Banques Populaires (BP) and Caisses d’Epargne (CE), co-constructed Groupe BPCE’s Impact strategy for the BP and CE and now oversees it, validating the orientations, priority projects and operational work plan.

An Impact function, coordinated and supported by the Impact department, manages and supports the sustainable transformation of the group’s business models and business lines to integrate ESG issues. Composed of all the group’s entities and business lines, it guarantees the co-construction, implementation of common guidelines and specific application to the specificities of each business model. It ensures the operational execution of the Impact strategic project.

Each group institution and business line has appointed an Impact sponsor, a function member, who drives and coordinates the Impact action plan at their company level and participates in the co-construction momentum.

Finally, the Federations play a specific role in structuring the Impact. The two retail banking and their cooperative shareholders are represented respectively by the Fédération Nationale des Banques Populaires (FNBP) and the Fédération Nationale des Caisses d’Epargne (FNCE), bodies that provide deliberation, communication and representation for the group’s institutions and their managers.

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

Concerning the members of the Management Board of BPCE SA

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%. The other qualitative criteria are assessed without any specific weighting.

For the 2026 fiscal year, the portion of qualitative objectives in the annual variable pay of the Chairman of the Management Board is 40%.

These “common objectives” reflect the 2026 KPIs of the VISION 2030 strategic project, and in particular those related to supporting the environmental transition and steering decarbonization trajectories, with a weight of 5% within the 40% (share of qualitative criteria).

For the 2026 fiscal year, the portion of qualitative criteria in the annual variable pay of the members of the Management Board is 40%. They consist for 30% to the “common objectives” of the Chairman of the Management Board and 10% to individual objectives.

• 1 Collective skills matrix of the Supervisory Board and term of office sheets for members.

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

1.4.4.1 Main features of the risk management and permanent control system related to the sustainability reporting procedure

Preparation and publication of sustainability information

In its capacity as the central institution, BPCE also monitors the correct application of group rules by required entities and validates their compliance with these rules. Within the group, the entities subject to the requirement to publish a sustainability report in 2025 are Natixis SA, BRED Banque Populaire and Banque Palatine.

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

• – A harmonized permanent control framework whose organization presented below in §1.4.4.2 is based on an approach similar to that one that prevails for financial information;
• – An ad hoc system for producing and handling sustainability data, including a dedicated organizational framework for sustainability reporting shared by all group entities, a process to aggregate all content to be published in the sustainability report, along with full supporting documentation. This ad hoc system is mainly driven by the Impact and group Finance departments.

In the context of preparing the sustainability report, the Impact department makes a more specific contribution to the following areas :

• CSRD acculturation: the Impact department has designed and rolled out acculturation sessions For different business lines’ employees (Purchasing, Governance, Compliance, etc.) and the management bodies of the group, subsidiaries and establishements. The educational objective of these sessions is to put CSRD and sustainability reporting issues into perspective, explain regulatory requirements and new structural concepts, and present their application at group level ;
• Double materiality assessment the Impact department shares responsibility with the ESG Risk department for identifying and rating Impacts, Risks, and Opportunities. All work, to which the group’s business lines (Retail Banking & Insurance, Natixis CIB, Natixis IM, BPCE Assurances) and central departments (in particular Human Resources, Finance, Purchasing, Compliance, Technology, and Operations) contribute, is coordinated by these two departments. Sustainability Office establishes the methodology for rating Impacts and Opportunities, with the ESG Risk department being responsible for risks
• Communication strategy and editorial content: the Impact department 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;
• Drafting of the transition plan;
• Coordination of the Banques Populaires and Caisses d’Epargne: the Impact department supports the institutions and defines a framework, guidelines and some content for the preparation of their voluntary Impact reports (non-regulatory report produced by certain institutions).

In 2024, the group Finance department (whose main missions are described in section 6.8 Quality control of accounting and financial information in chapter 6 Financial report of the URD) created a unit dedicated to managing non-financial issues closely related to the financial balance sheet. The Responsible Finance Steering (PFR) structure is part of the new “Impact Inside” model and plays a key role in coordinating the work of institutions on the Groupe BPCE sustainability report:

• Coordinating internal committee work and project governance, including interaction with other group entities that prepare their own sustainability report;
• Enhanced coordination around the data strategy and processes for producing the regulatory indicators required by ESRS, including the implementation of a testing system involving all producing 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 CNF (National Finance Committee) bodies;
• Interaction with the Board of Auditors.

Organization of the permanent control framework

The internal control framework 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 framework is designed, in particular, to ensure “[…] the reliability of financial and non-financial information reported both inside and outside the group.”

For the sustainability report, the internal control framework ensures compliance with the requirements defined by the Corporate Sustainability Reporting Directive (CSRD) and by the group in the context of the preparation and publication of reports and management metrics , which aims to harmonize reporting practices within the group.

To ensure strict independence in the implementation of controls, the permanent control framework is structured, as for all reports subject to permanent control, around two levels of controls.

First-level controls

First-level controls are carried out by all parties involved in the production and publication of the sustainability report. They consist of self-checking and control procedures put in place by each unit or entity participating in the processes, which formalizes its control results by identifying, where applicable, anomalies identified and the remediation plans to be implemented.

These first-level controls notably include:

• The drafting of a documentary corpus dedicated to the production of the sustainability report, describing the planned production process and first-level controls envisaged;
• The monitoring of compliance with regulations on the data to be published, which notably includes:

• – Reconciliations with the financial statements, if applicable,
• – Variation analysis,
• – A review of the quality of the data collected from external suppliers, where applicable,
• – A validation report associated with each metric.

In addition, and in accordance with the requirements of the CSRD (MDR-M1) regulations, the methods and main assumptions underlying the metrics, as well as the associated limitations, have been documented internally and reproduced in the sustainability report to provide the reader with all the background information necessary to understand the published metrics.

Second level controls : independent review of the sustainability report

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. For more details, see sub-section 6.8.3 “Accounting and financial data control process” of section 6.8 Controls of accounting and financial information quality in chapter 6 Financial Report of the Universal Registration Document.

With regard to the sustainability report, second-level controls are coordinated by group Financial Control (group Corporate Secretary’s Office) in conjunction with the group risk department and with the support of the Legal department. This review is based on a framework that mainly takes place in 4 main phases:

• 1) A risk assessment phase to identify the information and metrics to be monitored. This assessment is carried out mainly based on the results of the IRO (Impacts, Risks and Opportunities) rating carried out by the business lines on the metrics included in the sustainability report and by analyzing the internal control framework put in place for the various production processes for these metrics;
• 2) A phase of implementing - Second level controls based on six analysis axes focusing on the quality of documentation (including the double materiality assessment - DMA), the robustness of the organization regarding the production and publication of the report, the quality of the audit trail of the data and/or the metrics included in the reporting, the effectiveness of the Level 1 control framework, the accuracy of the data and/ or metrics published and their consistency with the information contained in other publications, and the clarity of the information;
• 3) A control feedback phase: the results of the controls are formalized and reported to the joint Cooperative & CSR Committee and the Audit Committee, in a summary that presents the work carried out and their conclusions, notably specifying the anomalies identified and, where applicable, the recommendations issued (or action plans or corrective measures);
• 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 framework for subsequent publications.

1.4.4.2 Key features of ESG risk management

Definition of ESG risks

Environmental risks

Environmental risks fall into two main categories:

• Physical risks arising from the impacts of extreme or chronic climatic or environmental events (biodiversity, pollution, water, natural resources) on the activities of Groupe BPCE or its counterparties;
• Transition risks arising from the impacts of the transition to a low-carbon economy, or one with a lower environmental impact, on 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, employees of the company’s value chain, communities concerned, end users and final consumers).

Governance risks

Governance risks arise from the impacts of governance factors on Groupe BPCE’s counterparties, notably including issues related to ethics and corporate culture (governance structure, business integrity and transparency, etc.), managing supplier relationships and influencing and business practices.

• 1 Minimum Disclosure Requirement - Metrics.

ESG risk management framework deployment program

The ESG Risk department coordinates the implementation of the ESG risk management frameworks at Groupe BPCE level through a dedicated program. This program is part of the VISION 2030 strategic project and defines a multi-year action plan (2024-2026) aimed at covering all regulatory requirements relating to ESG risk management. It is directly linked to the strategy and actions implemented by the Impact program. This program is monitored quarterly by the ESG Risk Committee and by the Groupe BPCE Supervisory Board.

This program is structured around the following four topics:

• Governance: committee procedures, roles and responsibilities, remuneration;
• Understanding of ESG risks: regulatory, sectoral and scientific watch framework, sector analyses and assessments, risk inventory, risk analysis methodologies and processes, data ;
• Strategy and risk management framework: in coordination with the other functions of the Risk department, consideration of ESG risk factors in their respective management frameworks and decision-making processes;
• Monitoring / communication : dashboards, contributions to RAF / ICAAP / ILAAP, training and acculturation plan for directors, managers and employees, contribution to non-financial communication.

In 2025, this program was subject to occasional adjustments to take account of the gradual framing of some projects and the regulatory expectations resulting from the EBA guidelines on ESG risk management.

The execution of this program mobilizes the main internal stakeholders in relation to ESG risks, in particular the Impact department, the other departments of the Risk department, the Finance department, the Compliance department, the Technologies and Operations department, the Digital & Payment 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 existing frameworks in the bank’s main risk functions.

The climate risk identification and assessment process is described in paragraph 1.5.1.1 Methodology for identifying impacts, risks and opportunities (IRO) in section 1.5 - Management of impacts, risks and opportunities of section 1 - General information.

Non-financial risks notably cover business continuity risks, reputational risks and legal risks. Reputational risk has been identified as material in the sections on Climate change, Own workers, Consumers and end-users, and Business conduct. These various risks are covered in the following sections:

Business continuity risks

Groupe BPCE’s incident tracking and operational risk monitoring tool makes it possible to specifically identify incidents related to climate and environmental risks, thus facilitating the continuous monitoring of their number and their financial repercussions.

As a preventive measure, as part of its business continuity framework, Groupe BPCE assesses the climate and environmental risks to which its main operating sites (head offices and administrative buildings) are exposed. These risks are taken into account as part of the business continuity plans defined at the level of Groupe BPCE and its entities. These define the procedures and resources to be implemented in the event of natural disasters in order to protect employees, assets and key activities and ensure the continuity of essential services.

Groupe BPCE’s essential, critical or important service providers (PECI) are also subject to an assessment of their business continuity plan, which must take into account the climate and environmental risks to which they are exposed.

Reputational risk

The management of reputational risk arising from ESG issues is fully integrated into the overall reputational risk management framework described in the dedicated section of the Pillar III report.

ESG issues are the subject of particular attention in Groupe BPCE’s main operational decision-making processes, such as credit granting or purchasing processes, in order to ensure compliance with its voluntary commitments (ESG sector policies in particular) and to identify controversies liable to involve the group. Specific crisis management mechanisms are also in place.

Reputation events related to ESG issues are subject to specific monitoring at Groupe BPCE level, carried out jointly by the Corporate Communications department and the ESG Risk department.

Legal risks

The legal risk management framework relating to ESG issues is part of Groupe BPCE’s overall legal risk management framework as well as the operational risk management framework, which includes the management of litigation and reputation risks. These frameworks define the governance mechanisms and procedures for escalating identified or actual litigation risks within Groupe BPCE.

The management of litigation risks in connection with ESG issues, and in particular climate and environmental issues, is notably based on a monitoring framework implemented by the Legal department on litigation affecting large corporations and in particular financial institutions. Based on this monitoring, a quantification of the risk, through the definition of fictitious standard disputes to which the group could be exposed, is carried out and integrated into the overall quantification of Groupe BPCE’s legal risk.

The risk prevention and control framework is based on existing decision-making processes to limit exposure to the risk of greenwashing and the risk of non-compliance with voluntary commitments as well as failures in the exercise of the duty of care.

ESG litigation involving Groupe BPCE is monitored quarterly by the ESG Risk Committee.

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 (IRO-1) Impact, risk and opportunity management

1.5.1 Double materiality assessment

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

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

1.5.1.1 Methodology for identifying impacts, risks and opportunities (IROs)

1.5.1.1.1 Methodology applied to all of the IROs

Various steps lead to the identification of IROs (impacts, risks and opportunities):

• 1) Identification of topics, and sub-topics:

• From ESRS 1 (AR 16.): identification has been carried out for topics, sub-topics and sub-sub-topics as defined in ESRS 1 (AR 16.). This work was carried out by mobilizing internal sources, such as the ESG issues identified in Groupe BPCE’s 2022 and 2023 NFPS reports and the 2024 sustainability report, 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 issues for banking players;
• Entity-specific: Groupe BPCE’s analysis is not limited to the sub-sub-topics of ESRS 1 (AR 16.); the use of internal and external sources also led to the identification of issues specific to the group’s banking and insurance activities. The following items have been identified as specific to Groupe BPCE and the resulting material IROs are included in the list of IROs (refer to Section 1.5.2 List of material IROs):

• – ESRS S1: the specific sub-topic: attractiveness, employee loyalty and engagement (including the specific sub-sub-topics: Listening to employees and strengthening their commitment, Integration of new recruits and employee loyalty, Recruitment strategy and employer brand),
• – ESRS S3: the specific sub-topic: Financing the economy and regional players,
• – ESRS G1: the specific sub-topic: fight against money laundering and the financing of terrorism and compliance with sanctions measures (national, European or international), embargoes and asset freezes.

In 2025, the relevance of the list of the group’s topics, sub-topics and sub-sub-topics was questioned. In view of the challenges facing the group and market practices, this list has not changed.

• 2) Formulation of Impacts, Risks and Opportunities (IROs): work to identify the IROs within each topic was carried out in order to cover both impact materiality and financial materiality. Several internal and external sources were used to identify the IROs. For the purposes of double materiality assessment, risks and opportunities generally arise from a positive or negative impact, or from the group’s dependence on resources and people.
• 3) Relevance of the IROs: the relevance of each IRO was verified with the business lines concerned to ensure that the listed IRO truly reflect a Risk, Opportunity or Impact for Groupe BPCE, to classify the Impacts as positive or negative within the same sub-topic and to avoid duplication between similar IROs. In 2025, the relevance of the IROs identified in 2024 was reviewed and work was carried out to group the IROs together to avoid the same subject being dealt with by several IROs of the same type.
• 4) Characteristics of the IROs: for each IRO identified, preaqualification was performed prior to their rating. This prequalification consisted of:
• a) Positioning each IRO in Groupe BPCE’s value chain, i.e. upstream, within its own activities, or downstream;
• b) Defining the potential or actual nature of the negative and positive impacts.

Taking account of the value chain in the identification of IROs

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

• Mapping of the group’s activities and the stakeholders in the value chain to identify which stakeholders are in at-risk areas;
• Completion of an analysis by major stakeholders families: clients, suppliers, subcontractors, etc.;
• Extension of 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 the completion of sectors analyses. Most of the group’s activities are focused on financing and investment activities (see presentation of the value chain in section 1.3.1.7 Value chain in section 1.3 Strategy).

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 Corporate ESG Risk and Corporate Impact departments. The Purchasing, Public Affairs, Retail Banking & Insurance, Compliance, Finance, Human Resources, Risk and Security teams of Groupe BPCE, Natixis and BPCE Assurances helped to formalize these IROs and assess them. This collaborative work makes it possible to assess the IROs of each scope and to assess the impact on the group scope of the IROs specific to a given business model.

The material IROs specific to the Natixis and BPCE Assurances business models have were rated at group level.

The identification, assessment and management of ESG opportunities have been integrated into Groupe BPCE’s overall process through the development and execution of the VISION 2030 strategic project.

1.5.1.1.2 Focus: climate and environmental risks (E1 IRO-1)

ESG risk identification and assessment process

Groupe BPCE has implemented a process to identify and assess the materiality of ESG risks in order to structure its understanding of the risks to which it is exposed in the short, medium and long term and to identify priority areas for strengthening the risk management framework.

This process is coordinated by the ESG Risk department, under the supervision of the Groupe BPCE ESG Risk Committee and Supervisory Board. It is subject to an annual review to update Groupe BPCE’s portfolios, scientific knowledge and underlying methodologies.

This process consists of four main steps:

• Creation of the risk inventory;
• Documentation of ESG risk transmission channels to other risk categories;
• Assessment of the materiality of ESG risks in relation to other risk categories;
• Input into cross-functional risk management exercises (risk appetite framework, ICAAP, ILAAP).

Group risk inventory

Groupe BPCE has set up an environmental risk inventory, which makes it possible to define the contingencies covered. This inventory is based on current scientific knowledge and baseline regulatory texts (e.g. European taxonomy) and aims for the most exhaustive possible representation of risks.

The climate and environmental risks included in the risk inventory currently defined by the group are presented below:

Climate and environmental risks

Risk transmission channels

ESG risks are risk factors underlying the other risk categories to which Groupe BPCE is exposed, namely credit and counterparty risks, market and valuation risks, insurance risks, structural balance sheet risks, strategic and business risks and non-financial risks (operational risks, reputational risks, non-compliance risks, insurance risks, etc.), as identified in Groupe BPCE’s risk taxonomy.

These transmission channels involve the impacts of climate risks on activities and business models, which are reflected in financial variables at the macroeconomic or microeconomic level and ultimately modify Groupe BPCE’s risk exposure. They may materialize directly, in connection with Groupe BPCE’s own activities, or indirectly, through the counterparties to which Groupe BPCE is exposed as part of its financing or investment activities. They are summarized in the following diagram.

1.5.1.1.3 Focus: IRO Nature (E2 IRO-1, E3 IRO-1, E4 IRO-1, E5 IRO-1)

The identification process for impacts of environmental risks, beyond climate change, at Groupe BPCE level has been 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 the scale of these impacts was carried out using the resources presented in section 1.5.1.2.2 Rating. With regard to risks, the rating was based, in particular, on a sectoral analysis of Groupe BPCE’s exposures as part of the assessment of the scale of impacts. The group has not, however, conducted specific direct consultations with potential affected communities.

The environmental risk identification and assessment process, beyond climate risks, is part of the same materiality assessment framework set up by Groupe BPCE as for climate-related environmental risks.

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

1.5.1.2 IRO rating methodology

After this initial identification step, the rating of impacts, risks, and opportunities – among all those identified as relevant – designates those that are material from an impact or financial perspective, and which are disclosed in this sustainability report.

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

Each impact, risk and opportunity has been rated, based on the criteria and scales described below.

1.5.1.2.2 Rating

Impact materiality rating

The impacts are rated by the contributors identified for each topic and the review is carried out cross-functionally by the Corporate Impact department.

For certain topics, specific resources have been used:

• For the rating of climate impacts via financing and investments, the group used the 2024 amount of GHG emissions and the group’s renewable energy exposures to assess the scale of impacts (E1);
• For the rating of Nature impacts (covering ESRS E2 to E5) via financing and investments, in 2025, the rating of these impacts was based on quantitative analyses using the ENCORE and MSCI databases and supplemented by an expert analysis. This work made it possible to quantify the extent of the group’s impact on nature by making the link between the sectors of activity in which the companies financed by the group operate and the intensity of the pressure exerted by each sector on the environment. These analyses cover exposures to the non-financial corporations in the FINREP scope (Banques Populaires, Caisses d’Epargne and Natixis CIB) supplemented by similar analyses carried out in the scope of BPCE Assurances (with ENCORE) and Natixis (with MSCI);
• To rate the negative impacts concerning ESRS S2, the group relied on a geographical analysis of its exposures (EU and non-EU) as well as a sectoral analysis of its exposures (sensitive sectors according to the OECD);
• To assess a positive impact on ESRS S3, Groupe BPCE relied on an external study that analyses the social and economic effects of the purchases made in 2024 from its French suppliers;
• For the rating of a positive impact concerning ESRS G1, the group relied on a questionnaire sent to its suppliers to measure their level of satisfaction with payment terms.

Financial materiality rating

Risk rating is carried out by the identified contributors for each subject and reviewed cross-functionally by the ESG Risk department. In 2025, the risk scoring methodology for the double materiality assessment changed compared to 2024. The rating of risks is consistent with the risk materiality assessment exercises carried out within Groupe BPCE, in particular, as part of Groupe BPCE’s risk appetite framework. It relies in particular on:

• The materiality analysis of climate and environmental risks (ESRS E1 to E5);
• The Human Resources risk mapping (ESRS S1);
• The monitoring of media events affecting Groupe BPCE (ESRS E1 to E5, S1 to S4 and G1 – IRO in connection with reputational and legal risks);
• The Compliance Risk Assessment System (ESRS G1).

This reference work is supplemented by expert opinion as part of the double materiality assessment in order to specifically qualify the risks selected (according to the scales of probability and scale defined above).

Focus: climate and environmental risks (E1 IRO-1)

Based on the transmission channels identified, Groupe BPCE assesses the materiality of climate and environmental risks in relation to the main risk categories to which it is exposed. This assessment distinguishes between physical risks and transition risks. It is carried out according to three time horizons: short-term (1 to 3 years, financial planning horizon), medium-term (strategic planning horizon, 3 to 7 years), and long-term (~ 2050).

This assessment is based on quantitative or qualitative indicators, which, when available, allow us to assess exposure to risks from a sectoral and geographical point of view, as well as on expert assessments. The internal experts involved in these assessments include the ESG Risk department,other unites within the Corporate Risk departement, as well as representatives from other departments (Impact, Compliance, Legal) and the business lines concerned.

In 2025, the materiality analysis was carried out at the Groupe BPCE level, simultaneously covering both climate and environmental risks. It was also applied at the level of the main operating entities, based on assumptions and a common analytical framework.

Integration into Groupe BPCE’s risk appetite framework

The work to identify ESG risks and assess their materiality feeds into the main components of Groupe BPCE’s risk appetite as part of this frameworks’s annual review process.

Groupe BPCE’s overarching risk cartography includes an “Ecosystem risk” category encompassing environmental risks (differentiating between physical and transition risks), social risks and governance risks.

The assessment of the materiality of these risk categories within the risk appetite framework is determined by cross-referencing the materiality of Groupe BPCE’s principal risk categories (assessed through the annual risk appetite definition process) with the materiality of climate and environmental risks relative to those categories. For social and governance risks, the assessment is carried out on an expert basis within the risk appetite definition process only.

These assessments make it possible to prioritize the issues related to each risk category, including those related to ESG risks. In 2025, the materiality of physical and transition environmental risks was assessed at level 1 out of 3 (“significant”) for Groupe BPCE, while the materiality of social and governance risks was assessed at a level of 0 out of 3 (“low”).

Use of scenarios

Within the framework of its planning and strategic steering processes for its business lines and risk management. Groupe BPCE uses climate scenarios to assess the challenges associated with short, medium and long-term climate risks.

These scenarios come from leading institutions in scientific research on the climate, such as the Intergovernmental Panel on Climate Change (IPCC), the Network for Greening the Financial System (NGFS) or the International Energy Agency (IEA).

The selection of the scenarios adopted by the group is based on cross-disciplinary work between the main departments involved in strategic planning and risk management. They are validated at the executive management level within the relevant bodies overseeing each of the various exercises in which these scenarios are used.

Scenarios used in risk management

Groupe BPCE mainly relies on the SSP2-4.5 scenario (IPCC) and Nationally Determined Contributions scenario (NGFS) to define a median trend for risk monitoring purposes.

For its risk assessment purposes in a deteriorated context, in stress test exercises for example, Groupe BPCE also relies on alternative, more extreme scenarios: SSP5-8.5 scenario (IPCC) on physical risk and Net Zero 2050 and Delayed Transition scenarios (IPCC scenarios) on transition risk.

ESG risk measurement tools and methodologies

In order to strengthen its ESG risk assessment capabilities, Groupe BPCE has developed specific methodologies that enable the systemactic and consitant evaluation of ESG risks associated with its exposure portfolios. These methodologies are based on internal and external expertise, and reflect the state of scientific knowledge, technologies and the current regulatory environment, as well as market practices. They are regularly reviewed, supplemented and enhanced to gradually improve the accuracy of ESG risk assessment and take account of changes in the overall context.

Assessment of environmental risks

Groupe BPCE’s physical and transition risk assessment methodologies are based on quantitative data supplemented by qualitative analysis where appropriate. They are described in the paragraphs below.

Physical environmental risk assessment

Geo-sectoral assessments

In order to strengthen the granularity and robustness of its assessments of the physical risk associated with its professional and corporate financing exposures, Groupe BPCE developed in 2024 a methodology to assess the vulnerability of these exposures to physical risks.

This internal methodology allows to take account of a sector’s intrinsic vulnerability to physical risks and the exposure of a given geographic area to these same hazards. It is currently based on a fine-granular sectoral level (NACE2) and a national or regional geographic grid covering countries in which Groupe BPCE has a particular concentration of exposures (France, United States). it currently covers six physical climate risks, which are among the most representative for Groupe BPCE, and can be simulated under different scenarios and time horizons.

Residential real estate portfolio

Given its high exposure to residential real estate portfolio, Groupe BPCE has developed a simulation tool for the physical risks to wich its financed assets are exposed. This tool uses the precise coordinates of each asset to assess its climate risk exposure, together with certain characteristics used to estimate its vulnerability, in order to determine estimated damages under different scenarios and time horizons. To date, this tool covers mainland France and Corsica and enables the assessment of exposure to the two main physical risks affecting this portfolio (drought – shrink–swell phenomenon observed with clay soils, and flooding).

Transition environmental risk assessment

Sector assessments

In order to enhance the granularity and robustness of its transition risk assessment associated with its professional and corporate financing exposures, Groupe BPCE developed in 2024 a methodology for the granular analysis of the sensitivity of different economic sectors to this risk.

This internal methodology allows to assign a sectoral score reflecting the transition risk associated with a given economic sector, taking account of the carbon emissions and the main environmental impacts of the companies in the sector in question. It has been developed in consistently with the Green Weighting Factor methodology (described below), which applies at the level of the company or financed project. Given the predominant share of French companies in Groupe BPCE’s portfolio of exposures (excluding Natixis), this methodology is focused on the parameters corresponding to the French economy.

Residential real estate portfolio

To assess the transition risk on its residential real estate portfolio, the Groupe BPCE relies on the Energy Performance Certificate (EPC) of the financed real estate assets. The EPC of financed assets in France is collected systematically, allowing to capture both the risk on the repayment capacity of the loan in the event of an increase in energy expenditure or expenses related to the financing of energy performance improvement, and the risk of loss of value of the asset due to a deteriorated EPC, making it potentially unfit for rent under current regulations.

Green Weighting Factor

Groupe BPCE notably uses the Green Weighting Factor (GWF) methodology, developed by Natixis CIB, to assess the transition risk related to its counterparties and financed projects.

Using a seven-color rating scale ranging from dark brown to dark green, the GWF assesses the climate impact of transactions, while taking account of the risk of the most material non-climate-related environmental externalities (water, waste, biodiversity, pollution). For the scope of Natixis CIB, this assessment is carried out on a granular basis for each of the financing exposures on the balance sheet for all banking products (loans, guarantees, sureties, documentary credits) regardless of their maturity, in all geographies and for all sectors of activity except the financial sector and administration. The GWF methodology is also adapted to Corporate or dedicated financing.

The GWF methodology offers a vision of the challenges of transition. The GWF integrates:

• The measure of induced decarbonization (CO₂e Scopes 1, 2 and 3);
• The contribution to the transition made by certain customers or active projects, with the notion of avoided emissions;
• The exposure to the most material non-climate environmental risks;
• A forward-looking view of the customers’ performance, making it possible to assess their transition potential;
• A set of new metrics useful for steering the decarbonization strategy of the Corporate & Investment Banking business unit and for regulatory reporting;
• The non-financial reporting needs of investor clients.

1.5.1.2.3 Calculation methodology

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

Impacts

The final impact rating is calculated using the following formula:

Final Impact rating = Likelihood of occurrence * Max (scale; extent; irremediability)

The items described below are applied in this step:

• Positive impacts: When the impact is positive, the irremediable character is not assessed and is therefore not taken into account in the calculation;
• Actual and potential impacts: The likelihood of occurrence is calculated when the impact is potential. In nearly all impacts identified by Groupe BPCE, the impacts materialized during the past fiscal year although not systematically at the upper threshold level (rated level 4);
• Final Rating: The final impact rating is within a range of 1 to 16, with 16 as the maximum score. The final impact score is divided by 4 to align it with the criteria rating scale, which stands at a maximum of 4. This is then called the final rating.

Risks

Risk ratings are determined by the combination of two axes evaluated from 1 to 4 (probability, scale). Consistent with the risk appetite framework, final risk ratings are set on a scale of 0 to 3 according to the matrix below, defined by the combination of the two axes (likelihood, scale). Thus, each rating combination (example: probability = 1 = rare, scale = 2 = significant) is associated with a result from 0 to 3 in the matrix (for the example cited above, the result = 0 = non-material). All possible combinations are detailed in the matrix, section 1.5.1.2.5 Determination of materiality thresholds – Materiality threshold for risks.

Opportunities

The final opportunity rating is calculated using the following formula:

Final Opportunity rating = Likelihood of occurrence * Scale of financial impact

The item described below is applied in this step:

• Final rating: The final opportunity rating is within a range of 1 to 16, with 16 as the maximum score. The final impact score is divided by 4 to align it with the criteria rating scale, which stands at a maximum of 4. This is then called the final rating.

1.5.1.2.4 Determining materiality thresholds

Groupe BPCE’s materiality thresholds are defined by the CSRD Project Steering Committee.

Materiality threshold for impacts and opportunities

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

Materiality threshold for risks

In 2025, the risk materiality threshold was modified to align with the group’s risk appetite framework.

In the double materiality assessment, any risk with a score of 1, 2 or 3 in the matrix (presented below) is considered material.

1.5.1.2.5 Results

Material ESRS in 2025

Changes 2024/2025

Between 2024 and 2025, ESRS S2 (Value Chain Workers) became non-material for the group: given its activity strongly rooted in the territories and its value chain, the impacts mainly concern working conditions rather than human rights. This understanding has led business line experts to reassess the probability of these impacts downwards for the group.

For the 2025 ass, as mentioned in the IRO identification section, Groupe BPCE has grouped together, where relevant, the IRO identified in 2024 which concerned the same sub-topics or sub-sub-topics, in order to avoid potential redundancies.

1.5.1.3 Stakeholder consultation

Although stakeholder consultation is not mandatory within the double materiality exercise, Groupe BPCE deemed it important to specifically seek input from certain stakeholders, in addition to the existing permanent listening frameworks. The ad hoc analysis frameworks deployed in 2025 concern responses to the NPS (Net Promoter Score) questionnaires intended for clients and questionnaires intended for the group’s suppliers.

1.5.1.4 Governance of the double materiality assessment

Role of the Corporate Impact and ESG Risk departments

• The Impact department has established the methodology for rating impacts and opportunities on behalf of the group.
• The ESG Risk department has established the risk rating methodology on behalf of the group.

The Impact and ESG Risk departments have coordinated and supervised the IRO rating project on behalf of the group.

Operating procedure for rating IROs

Groupe BPCE’s Impact and ESG Risk departments proposed the methodological approach for rating IROs within the “CSRD Project”.

Several functional department were called upon within the rating the IRO rating process. These notably include the following corporate departments:

• Purchasing;
• Retail Banking and Insurance;
• Compliance;
• Impact;
• Legal;
• Human Resources;
• ESG Risk;
• Operational Risk;
• Technology and Operations;

Workshops have been held with the business lines of the various entities (Groupe BPCE, Natixis, BPCE Assurances) to discuss the structuring options for IRO rating and to co-construct a common approach. In this context, they were sent a group operating procedure.

Process for validating the ratings of impacts, risks and opportunities

The validation of IROs is first carried out through workshops bringing together representatives of the business lines concerned by each topic and sub-topic, then by the Management Board and finally by the CSR Cooperative Committee.

Internal control

In 2025, an internal control framework was rolled out for the double materiality assessment. This framework relies on the implementation of a number of first-level controls, notably:

• Hierarchical control: each business line contributor must ensure that all expected information in the IRO rating file is entered correctly and must have the list of relevant and material IROs validated by their line manager.
• An analysis of changes between fiscal years: each business line contributor must justify changes in IROs between N-1 and N, by highlighting: new IROs (inputs), IROs considered irrelevant/immaterial in N (outputs) and justify these changes.

In addition, second level 2 controls are performed on the double materiality assessment in line with the approach implemented as part of the independent review of the sustainability report (see section GOV-5 Risk Management and Internal Controls on Sustainability Information).

1.5.1.5 Review process

The sustainability report is prepared on an annual basis. If Groupe BPCE concludes, on the basis of substantive 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 verifies the elements that may trigger a revision of the list of material IROs, for example, a major merger and acquisition transaction leading to the creation of a new activity, an entry into a new sector or a significant change in operations, a global event (pandemic, natural disaster, etc.), or a change in scientific evidence liable to affect the severity criteria.

1.5.2 List of material IROs

1.5.3 (SBM-3) Material impacts, risks and opportunities and their interaction with the group’s strategy and business model

The material impacts, risks and opportunities (IROs) resulting from the double materiality assessment are listed in section 1.5.1 (IRO-1) Management of impacts, risks and opportunities. This description makes it possible to identify where these material IROs are concentrated in its business model, its own activities or its value chain.

The business model, value chain and integration of sustainability issues into Groupe BPCE’s strategy are detailed in section 1.3.1.2 Objectives in terms of sustainability.

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.

The current financial effects of material risks are recognized in Groupe BPCE’s financial statements as impairments related to the effects of physical and transition risks on credit risk. These impairments have been defined by the institutions according to the specific characteristics of their credit exposure portfolio, from a geographical and sectoral point of view, when the risk was assessed locally as a material risk. Expected credit losses on climate risks have also been recognized. These provisions anticipate direct losses, by sector or by geographic area, caused by extreme or chronic weather events resulting in an increased risk of default following a cessation or reduction in activity. Account may also be taken of transition risks in these expected credit losses. The methods used to determine these impairments are detailed in Groupe BPCE’s consolidated financial statements: Note 2.3 Use of estimates and judgments and Note 7.1.2. Change in gross carrying amounts and expected credit losses on financial assets and commitments.

With respect to climate risks, Groupe BPCE analyses 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) with regard to the risks it may face. This analysis is presented in Chapter E1 - Climate change in section 2.2.6.2 (ESRS SBM-3) Resilience of the strategy and business model.

Part 2 Environmental information

2.1 Indicators of the European taxonomy on sustainable activities

Regulatory framework

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

The Taxonomy Regulation (Article 8) includes, for companies subject to the CSRD (Corporate Sustainability Reporting Directive published on December 16, 2022), a reporting obligation, outlined in the sustainability report, regarding how and to what extent the company’s activities are associated with economic activities that can be considered environmentally sustainable.

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

• Climate change mitigation;
• Climate change adaptation;
• Sustainable use and conservation of aquatic and marine resources;
• The transition to a circular economy;
• Pollution prevention and control;
• Protection and restoration of biodiversity and ecosystems.

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

• Demonstrate its substantial contribution to one of the six environmental objectives in accordance with the technical review criteria defined in the delegated acts;
• Demonstrate that it does not cause significant harm to any of the other environmental objectives (Do No Significant Harm or DNSH) in accordance with the technical review criteria defined in the delegated acts;
• Be carried out in compliance with the minimum social guarantees set out in the regulations (i.e. in compliance with the social rights guaranteed by international law).

The technical requirements for doucmenting an activity’s environmental sustainability were initially defined in the Green Taxonomy regulatory framework (EU) 2020/852 and subsequently modified by delegated acts:

• The Climate Delegated Regulation of June 4, 2021 (2021/2139), including technical review criteria for economic activities that make a substantial contribution to the first two environmental objectives: adaptation to climate change and mitigation of its effects. It has been effective since January 1, 2022.

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

A second amendment was published on June 27, 2023 (Delegated Regulation 2023/2485) completing the technical examination criteria for certain activities that were initially not listed as eligible (in particular, the manufacture of essential equipment for low-carbon transport or electrical equipment). It has been in force since January 1, 2024:

• The Environment Delegated Regulation of June 27, 2023 (2023/ 2486) sets the criteria for the technical examination of economic activities deemed to make a substantial contribution to one or more of the four other environmental objectives (other than climate): Sustainable use and conservation of aquatic and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems. It has been in force since January 1, 2024.

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

Additional information is required for companies engaged in, financing or exposed to specific activities related to nuclear energy and fossil gas (Delegated Regulation 2022/1214).

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

On December 21, 2023, the Commission published a communication on the interpretation and implementation of Article 8 of the Taxonomy, which further specifies the information to be provided. It was published in the Official Journal of the European Union on November 8, 2024 under the reference C/2024/6691. On November 29, 2024, the Commission published a new draft communication. Given its late publication and the implementation work involved, this text is currently being analyzed, and some of its provisions will be applied in the coming period.

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

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

This year, Groupe BPCE has not applied the new delegated act of July 4, 2025 amending the Taxonomy Regulation in accordance with the provisions of the applicable text.

Consideration of the taxonomy within the framework of the group’s activities (requirement of Annex XI of Delegated Regulation 2021/2178)

The taxonomy criteria are used to identify a portion of the financial assets allocated to green bonds issued by Groupe BPCE. Groupe BPCE also takes account of the European Taxonomy in the design of some of its “green” offers and services and in its project financing (renewable energy financing).

KPIs of material non-banking subsidiaries

The group’s material non-banking activities are insurance activities, of which BPCE Assurances is the main entity. The KPI relating to asset management activities is also published via the GAR AuM in the section “Off-balance sheet indicators: financial guarantees given and assets under management” below.

BPCE Assurances’ ratios are detailed below:

Non-life underwriting ratio of BPCE Assurances:

Non-life insurance has been defined as eligible for Objective No. 2 “Climate change adaptation”. The underwriting ratio, indicates the share proportion of premiums that meet the technical criteria relating to climate change adaptation, (expressed as a percentage of total premiums).

Investment ratio of BPCE Assurances:

The calculations of investment eligibility and alignment ratios are carried out by weighting the investments according to the proportion of economic activities that are eligible and aligned with the taxonomy, based on two financial indicators of the invested companies: revenue and capital expenditure (CapEx).

For BPCE Assurances’ euro and similar funds (excluding unit-linked funds), the proportion of eligible investments aligned with the taxonomy is presented in the table below:

Assumptions used and existing limitations in the preparation and collection of information

The different KPIs required by the regulations have been published as follows:

Information on the main KPI (“Green Asset Ratio”) has been published.

The “financial conglomerate” KPI has not been published. BPCE considers that it is not subject to this indicator, which is not defined by the Delegated Regulation.

The main exempt entities are the Banques Populaires and the Caisses d’Epargne. As the activity profiles of the BPs and CEs are homogeneous with those of the group, the summary of the GARs of the BPs and CEs is not disclosed.

The KPIs of non-financial subsidiaries have not been published because they are not material.

The flow information on the KPIs of off-balance sheet exposures has not been published due to the absence of a dedicated table in Annex 6 of the Delegated Regulation.

The main assumptions used to determine the alignment of eligible assets under the Green Asset Ratio (GAR) are as follows:

For real estate loans granted to households, the alignment is based on:

• 1) Analysis of the energy performance of assets through the EPC or compliance with thermal regulations for new assets (RT2012 and RE2020) in order to measure the substantial contribution;
• 2) An analysis of the physical risks, including only the “flooding” risk in order to verify that the criteria of the DNSH adaptation are respected: any loan relating to an asset exposed to a significant physical risk is thus considered to be unaligned with the taxonomy;
• 3) Minimum social guarantees are deemed to be met for all assets built in France and Europe, taking account of the laws and regulations in force in these countries.

The alignment of the following eligible assets has not been analyzed: loans for the renovation or financing of motor vehicles with individual customers as well as financing allocated with CSRD counterparties. These assets are therefore de facto considered as not taxonomy-aligned.

Given their immaterial impact on the GAR, no account has been taken of eligibility and alignment aspects related to the fair value of the insurance subsidiaries’ equity method investments.

Given the immaterial nature of the exposures relating to gas and nuclear energy only the information on the main KPI (Green Asset Ratio) has been disclosed. Information on other KPIs (flows, off-balance sheet exposures) has not been disclosed.

The table relating to the alignment of fees and commissions and the trading book has also not been published.

Mandatory GAR

Main indicator – GAR (Green Asset Ratio)

Groupe BPCE’s GAR at December 31, 2025 includes taxonomy alignment data. It is presented in the tabular format required by the regulations of the version currently in force. This requires that it be disclosed once on fusing the “Revenue” KPI (key performance indicator) and once using the “CapEx” (capital expenditure) KPI for counterparties subject to the CSRD.

Groupe BPCE’s GAR established on December 31, 2024 listed information on alignment with two environmental climate objectives (Mitigation and Adaptation). For 2025, the group has included information on alignments with the other four objectives (sustainable use and protection of water and marine resources; transition to a circular economy; pollution prevention and control; protection and restoration of biodiversity and ecosystems) in the GAR calculation. Data on aligned assets is published as soon as it is available on Bloomberg.

Information on eligibility for the four non-climate objectives (sustainable use and protection of water and marine resources, transition to a circular economy, pollution prevention and control, protection and restoration of biodiversity and ecosystems) is based on data published by non-financial corporations. As a result, on December 31, 2025, Groupe BPCE provides this information along with a presentation of the columns in the regulatory tables relating to this information.

The GAR Flows KPI shows the portion of assets aligned over the portion of assets covered by the GAR only for new outstanding loans and advances and debt securities recognized on the balance sheet since the beginning of the period (in our case, January 1, 2025). Outstandings are recorded at gross carrying amount (before impairment, provisions and amortization) and without deduction of repayments or sales of assets during the period. Given their immaterial nature, the GAR Flows KPI is not calculated on equity instruments (e.g. equities). Likewise, the “flows” KPIs for financial guarantees and assets under management are not published for operational reasons. The other calculation principles remain identical to those applied for the calculation of outstandings.

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

Scope of financial assets subject to eligibility and alignment analysis

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

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

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

• Financial assets at amortized cost, financial assets at fair value through other comprehensive income, financial assets designated as measured at fair value through profit or loss and non-trading financial assets measured at fair value through profit or loss;
• Investments in subsidiaries, joint ventures and associates (controlled insurance companies are accounted for using the equity method for the presentation of the regulatory perimeter);
• Fixed assets, with regard to collateral obtained by taking possession.

Methodology used

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

• For financial and non-financial counterparties subject to the CSRD regulations, as identified from the database provided by Bloomberg:

• – for unallocated financing, taxonomy alignment and eligibility rates (Revenue KPI and CapEx KPI) available in Bloomberg are applied to the gross amount outstanding. These data correspond to the indicators published by these counterparties in the previous year (determined in accordance with the criteria of the Climate and Environment Delegated Regulations). BPCE relies solely on Bloomberg’s exact counterparty data and excludes all estimated figures. Conversely, BPCE does not use Bloomberg estimates. Finally, in the absence of available data distinguishing eligibility and alignment rates by environmental objective, they have been allocated to the climate change mitigation objective,
• – for allocated financing, the taxonomy criteria defined by the European Commission should be analyzed on the basis of the information provided by the counterparties. For the 2025 fiscal year, Groupe BPCE did not conduct these ad hoc analyses.

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

• For retail customers (or households):

• – The exposures subject to analysis are: Loans guaranteed by residential real estate (including secured loans); renovation loans and loans for motor vehicles granted from January 1, 2022,
• – The alignment of loans guaranteed by residential real estate (or secured) is determined in the light of criteria laid down by regulations and interpretations accepted by the marketplace. The substantial contribution to the first taxonomy objective of climate change mitigation is documented with regard to the following criteria: