5692019 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

Duty of care and Modern Slavery Act and human trafficking statement

7.6. Duty of care and Modern Slavery Act and human trafficking statement

DUTY OF CARE: 2019 BNP PARIBAS VIGILANCE PLAN

REGULATORY FRAMEWORK Law no. 2017-399 of 27 March 2017 on the Duty of care of parent companies and of companies using sub-contractors applies to the Group as a whole and requires a vigilance plan to be established and implemented to identify and prevent the risk of serious violations of human rights and fundamental freedoms, and of harm to human health and safety and to the environment. Starting with the 2018 financial year, the law also requires the preparation of a report on the effective implementation of the Group s vigilance plan.

GOVERNANCE Initiated and overseen by Group Management, the Corporate Social Responsibility (CSR) policy is a strategic issue for BNP Paribas. It reflects a commitment at the highest level of the Company, to combine performance, responsibility, ethics and transparency. CSR objectives were included in the Group s 2017-2020 business development plan.

Actions related to Group vigilance measures are defined by the CSR Function and jointly designed with the relevant stakeholders concerned in the main businesses and functions: Domestic Markets, International Financial Services, Corporate & Institutional Banking, Group Human Resources, Group Strategic Sourcing, Compliance, Risk and Legal. These actions are intended to cover all of the Group s businesses, functions and countries of operation. In 2019, deployment of these previously defined action plans has continued, under the auspices of the Heads of the relevant businesses and functions, who are members of the Group Executive Committee.

The Group is committed to promoting compliance with a number of the principles and standards that underpin its operations, such as the United Nations Sustainable Development Goals (SDGs), the 10 principles of the United Nations Global Compact, and the standards defined by the International Labour Organization (ILO).

For the analysis of environmental, social and governance (ESG) risks, the CSR Department relies on the various businesses, which constitute the first line of defence. The Group CSR Function supports businesses in the most complex analyses, providing its thematic and industry expertise. The Risk Management Function acts as a second line of defence for CSR assessments as part of the credit and investment decision-making process. Within its risk appetite framework, the Group has, since 2014, provided the breakdown of the electricity and energy mix which it finances, which are lower in carbon that the global mix.

Executive Management made a series of commitments on the environment as of 2011, and on human rights as of 2012, by signing the Declaration of Human Rights. In 2016, the Group s management reiterated its strong commitment to respecting human rights and protecting the environment through the publication of its Code of conduct applicable to all employees around the world. The latest update was published in 2018.

Furthermore, the purpose of the Group s ethics warning system is to enable any BNP Paribas employee to report a proven breach or a suspicion of such a breach of the Code of conduct, of a policy or of a Group procedure or regulation, not only to their line management, but also, alternatively, to the compliance team of the entity to which they belong, or of a higher level. Employees have the right to report wrongdoing internally and may not be punished in any way for doing so in good faith.

Any suspicion by a BNP Paribas employee of serious or potentially serious violations of human rights and fundamental freedoms, and of harm to human health and safety and to the environment, may be reported under this ethical alert system.

OUR VIGILANCE APPROACH

Scope

As part of the preparation of its vigilance plan, BNP Paribas conducted, consistent with its commitments, risk mapping and a review of its existing risk assessment and control policies and tools, on a scope consistent with the text of the law.

This scope includes employees (Human Resources (HR)), suppliers and sub-contractors (Group Strategic Sourcing (GSS)) and the main business lines within the three principal BNP Paribas divisions (Domestic Markets, International Financial Services, Corporate & Institutional Banking).

Risks taken into account in the development of different mapping exercises

In line with its CSR commitments, the Group has included in its vigilance approach the risks of serious violations of human rights and fundamental freedoms, and of harm to human health and safety and to the environment, and the following issues in particular:

■ issues related to human rights and fundamental freedoms: child labour, forced labour and human trafficking, non-compliance with the rights of local communities, freedom of association and collective bargaining, exercise of the right to strike, discrimination, failure to respect the rights of local communities, harassment, unfair wages and excessive hours of work;

■ issues related to human health and safety: workplace and consumer health and safety;

■ environmental issues: air pollution, water pollution, soil pollution, scarcity and depletion of commodities, water scarcity, erosion and soil depletion, waste management, greenhouse gas emissions, degradation of ecosystems and biodiversity.