Universal registration document and annual financial report 2020

2020 Universal registration document and annual financial report - BNP PARIBAS620

a Committed Bank: information ConCerninG the eConomiC, soCial, CiviC and environmental resPonsiBility of BnP PariBas Duty of Care and Modern Slavery Act and Human Trafficking statement

These public commitments are backed by internal policies implemented at Group level, with the goal of handling the many subjects revolving around social, environmental and governance matters, including human rights. These policies include:

■ BNP Paribas Group Code of Conduct;

■ The BNP Paribas statement on Human Rights;

■ The BNP Paribas Suppliers CSR Charter;

■ The BNP Paribas Responsible Business Principles.

Early and efficient identification of modern slavery risks is the first step towards its prevention, alleviation and remediation, and calls for specific policies and practices. In this regard, BNP Paribas has taken the following steps and actions in order to exert its duty of care with all due seriousness.

Towards its employees

BNP Paribas is committed to providing a working environment in which all employees are treated fairly. In particular, the Group focuses on respect and the need to apply the most stringent norms of professional behavior, and rejects all forms of discrimination. The Group s existing policies and procedures notably include an annual review of high-risk countries in terms of human rights, as well as a monitoring of employees aged between sixteen and eighteen (one employee in 2020, in Brazil). Further, the Group s Diversity policy and remuneration principles reaffirm the application of non-discrimination principles in the recruitment and career management of its employees. The BNP Paribas Code of Conduct, which sets out rules which must be understood and followed by all employees, confirms the Group s commitment against harassment, including sexual harassment.

In line with these policies and principles, all employees of the Group are required to treat their colleagues with respect, make sure their interactions are professional and efficient, and be receptive of their contributions, even if they express different views from their own.

The BNP Paribas agreement on fundamental rights and the establishment of global minimum social standards, signed with the UNI Global Union on 18 September 2018, sets up an ambitious plan to fight against inequalities and improve the working conditions of the Group s employees.

Awareness and Training BNP Paribas took part in the development of an awareness-raising e-learning module called Business and Human Rights , co-created with the other members of the French association Entreprises pour les Droits de l Homme (Enterprises for Human Rights EDH). This e-learning module is mandatory for all employees who directly contribute to the promotion of human rights including Risk teams, Procurement business areas, business relations officers in Corporate and Institutional Banking (CIB) and the CSR network, and is accessible to all Group employees.

Raising concerns BNP Paribas employees are required to report any effective or suspected breach of the Code of Conduct, Group policies and procedures, or regulations.

If they cannot send their report to their manager or through another usual channel, they have the option of raising an ethics alert, in accordance with the whistleblowing procedure in force within the Group.

Any problem concerning a violation or a suspected violation of human rights within the framework of the activities of the Group or of its supply chain can be reported by an ethics alert, except when specified otherwise by local regulations or procedures.

Our ethics alert policy guarantees employees exercising their right to ethics alert protection against the risk of reprisals for having launched an internal alert in good faith

Towards its suppliers

Within Group Strategic Sourcing Function, dedicated teams address CSR risks linked to suppliers and subcontractors.

BNP Paribas ESG risk management related to its suppliers and subcontractors hinges around the following elements:

■ a responsible purchasing policy that aligns the Function's objectives with the Group's CSR objectives, as expressed in the Group purpose (raison d'être);

■ the definition by the Function of a normative reference framework, which includes:

■ an ESG risk mapping tool encompassing thirteen themes, including modern slavery and child labour, allowing the identification of procurement categories at high environmental or social risk;

■ a Sustainable Sourcing Charter , setting out the reciprocal commitments of the Group and its suppliers and subcontractors from an environmental and social standpoint;

■ contractual clauses requiring compliance with the ILO conventions in supplier contract standard templates in all countries where suppliers are located, allowing contract termination in case of non-compliance by the suppliers of the Group ESG requirements;

■ ESG questionnaire models, used during calls for tenders and including environment, ethics and human rights targeted questions;

■ supplier monitoring rules, targeting ESG criteria used during the selection process and completed by the thematic regulatory watches;

■ training of Procurement function employees.

In 2020, BNP Paribas also completed its system by launching, with three other banks and a third party assessor, an on-site audit of two categories of purchases.