5252019 Universal registration document and annual financial report - BNP PARIBAS

7 a Committed Bank: information ConCerninG the eConomiC,

soCial, CiviC and environmental resPonsiBility of BnP PariBas

7

Our economic responsibility: financing the economy in an ethical manner

COMMITMENT 2: ETHICS OF THE HIGHEST STANDARD

The respect of the most rigorous ethical standards is a prerequisite at BNP Paribas. All Group employees are required to strictly respect all laws, rules and regulations in effect, as well as all professional standards that apply to their activities. In the event of conflict between the laws of a country and BNP Paribas ethical rules, the Group s employees are required to respect local legislation while at the same time looking for ways to apply and respect internal ethical rules.

ETHICS OF THE HIGHEST STANDARD

Code of conduct

In May 2016, BNP Paribas published and distributed to all its employees its new Code of conduct supplemented in 2018 by a more specific section on anti-corruption. It is accessible to everyone on the Group s website(1). Mandatory online training in the Code of conduct was delivered in 2016, and has continued since then for new hires.

The whistleblowing system

BNP Paribas has a dedicated internal ethics alert (whistleblowing) system, based on dedicated communications channels, available to employees on the intranet. Every employee has the right to report ethics violations without fear of punishment, dismissal or discrimination for the simple fact of having made use, in good faith, of this system.

The whistleblowing system is subject to continuous improvement measures. It was reviewed in 2018 to meet new regulatory standards (Sapin 2 Act, MiFID 2 and Duty of care) and to strengthen protection for the whistleblower: through a thematic memo sent to all employees, the communication of rules, and the creation of a dedicated forum for whistleblowing referents (employees tasked with the reception and processing of ethics alerts), in order to standardize the handling of these cases.

The fight against corruption and money laundering

In terms of financial security, as part of its transformation programme, the Group strengthened the Anti-Money Laundering/Combatting the Financing of Terrorism (AML/CFT) system by updating several key elements of its regulatory framework. The operational implementation of the new standards on transaction monitoring and the management of AML/CFT alerts defined in 2017 continued throughout the Group and had been completed by end of 2019 in most of the entities concerned.

The BNP Paribas corruption prevention and management system was overhauled following the publication of the so-called Sapin 2 Act of 9 December 2016 on transparency, anti-corruption and modernising the economy. Governance has been consolidated through the increased role of points of contact in our business lines and functions. The corruption risk framework methodology has been revised to cover new processes

(Know Your Supplier, lobbying and governance). Third-party due diligence policies have also been strengthened, the disciplinary process clarified and numerous awareness and communications measures launched to ensure that all parties are committed to combating corruption. Lastly, all employees have now completed awareness training on related risks.

Training

At end 2019, 94.4% of the 178,442 employees concerned had followed online training on international sanctions and embargoes, while 94.1% of the 167,569 employees concerned had received anti-money laundering and financing of terrorism training.

Regarding competition law, 94.5% of the Group s employees (not accounting for exempted individuals) passed the Competition Law and You training at the end of 2019.

Finally, in 2019 the Group relaunched the Know Your Data (KYD) training as part of the mandatory Compliance training programme. 91.3% of the 192,790 eligible employees completed this training. Moreover, 87% of employees from the European Economic Area completed their Personal Data Protection training in 2018. The training is due to be rolled out again in 2020.

The fight against tax evasion

The amount of taxes and duties due by the Group stood at EUR 5.9 billion in 2019, including EUR 2.5 billion in France.

Each year, the Group publishes a detailed report on its locations, showing all relevant data, country by country, including net banking income, headcount, results and taxes paid. It is clear from the data that the location of its offices is not driven by tax considerations, but guided in the interest of best serving its customers around the world. (see Information on locations and businesses, Chapter 8, section 6).

To this end, BNP Paribas ensures that its entities do not benefit unduly from privileged tax schemes. Moreover, the Group avoids locations in States or territories considered uncooperative by France or the official bodies of which France is a member (European Union, OECD).

Incidentally, the tax authorities around the world have all of the information they need to ensure that the Group is making its fair contribution to covering public expenses in every country in which it does business.

In addition, the Group pays close attention to customer compliance with tax laws. Thus, international private banking requires its non-resident customers to fill out a tax compliance statement . More generally, the Group contributes to customer compliance with tax obligations due to its role of tax collector and provider of information to the tax authorities and to the taxpayers themselves.

(1) https://group.bnpparibas/uploads/file/codeofconduct_en_11_01_2018_40p.pdf.