570 2019 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

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Duty of care and Modern Slavery Act and human trafficking statement

Systems used to manage these risks

The Group made an inventory of its existing systems, and compared them against the elements required for the preparation of the vigilance plan, ensuring that these existing systems fully covered the main risks for employees, suppliers and banking and financial activities.

Risk mapping covered, inter alia, purchase categories for the Group s suppliers, as well as business sectors and operating countries for BNP Paribas banking and financial activities. Analysis grids, in addition to the existing risk prevention systems, were developed and tested.

OUR EMPLOYEES The Group wants to foster a stimulating work environment in which every person is treated fairly. In particular, the Group places an emphasis on respect, the need to apply the highest standards of professional behaviour, and the rejection of all forms of discrimination. The Group also ensures the safety and security of people in their workplace.

When it implemented its vigilance plan, BNP Paribas ensured that there was adequate coverage of all salient risks(1) as well as formalising them in existing Group HR policies.

The Group s diversity and inclusion policy and remuneration principles reaffirm the principle of non-discrimination in the recruitment and professional development of employees up to the Company s highest levels. These policies are supported by the Group HR control plan as well as by a specific alert procedure on discrimination issues via Discrimination advisers , who can be called upon, in the countries where they exist, by any employee who believes he/she is a victim of discrimination.

■ BNP Paribas has also signed the 10 Principles of the International Labour Organisation s Disability Charter, designed to promote the employment and working conditions of people with disabilities. By means of the Global agreement (signed in September 2018 with UNI Global Union), each of the Group s entities has undertaken to implement at least one of 10 commitments from the aforementioned Charter.

■ As part of the UN Women HeForShe programme, BNP Paribas is especially committed to advancing gender equality by beginning to better balance male and female representation in roles that historically had a preponderance of female (HR) or male (Global Markets) employees.

■ BNP Paribas also supports the United Nations LGBTI Standards of Conduct, unveiled in September 2017 to combat discrimination against LGBTI people at work.

The update of the Code of conduct in 2016 strengthens the Group s commitment to combating harassment, including sexual harassment. The Human Resources Department also introduced an internal procedure in 2018 on how to deal with reports of harassment. Under the Global agreement, this will be implemented in all Group entities, together with measures to support victims.

The European Social Charter, from which derives the European agreement on the prevention of stress at work (which has applied since 2017), the

programmes related to the prevention of psychosocial risks and stress at work, the commitment on maternity/paternity, the charter on the balance of professional life and personal life in France and new ways of working all contribute to a better balance of work patterns.

In 2018, BNP Paribas also updated its HR personal data protection policy to apply the provisions of the General Data Protection Regulation (GDPR), which came into force on 25 May 2018, and carries out awareness-raising activities for employees in the territories where the GDPR is applicable.

Occupational risk prevention programmes and occupational health and safety policies are adapted to the specificities of the Group s different business lines; they are described in more detail in paragraph 7.3.

The policies and actions already undertaken by Human Resources will continue to be implemented and monitored over time.

OUR SUPPLIERS AND SUB-CONTRACTORS Dedicated teams in Group Strategic Sourcing deal with supplier-related ESG risks.

In accordance with the deployment of the Act, BNP Paribas ESG risk management system for its suppliers and sub-contractors is based on the following elements:

■ an ESG risk map covering 13 issues and identifying purchasing categories that carry a significant amount of environmental and social risk;

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

■ standard contractual clauses covering requirements in order to meet environmental and social criteria. Since 2018, they have also included the option of ending contracts if suppliers do not comply with the Group s ESG requirements;

■ standard ESG questionnaires used in calls for tenders to assess suppliers;

■ supplier risk monitoring rules, targeting certain ESG criteria used during selection, supplemented by monitoring and completed by intelligence in different areas;

■ training for the Sourcing business.

Also see Fostering dialogue with stakeholders in Our strategy, part 7.1, and Systematic integration and management of Environmental, Social and Governance risks (ESG), Commitment 3.

In France, BNP Paribas as a signatory of the Responsible Supplier Relations Charter promoted by the Business Mediation body of the French Ministry of Economy and Finance, has an independent internal procurement mediator to offer advice in the event of a dispute, whose contact details are provided on the Group s institutional website.

The use of ESG evaluation questionnaires in calls for tenders and the inclusion of their results in the overall evaluation of the supplier form part of the Strategic Sourcing control plan.

In addition, the GSS business has set up an annual reporting process so that the progress made by entities can now be assessed.

(1) Salient is the term used by the drafters of the United Nations Guiding Principles Reporting Framework.