Universal registration document and annual financial report 2019

5732019 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

Duty of care and Modern Slavery Act and human trafficking statement

MODERN SLAVERY ACT AND HUMAN TRAFFICKING STATEMENT

INTRODUCTION This Statement(1) relates the steps that BNP Paribas has taken to ensure that human trafficking(2) and slavery(3) are not taking place in its direct operations or supply chains. It also refers to the risk management that the Group has put in place in the context of its financing and investment activities, which govern the potential cases of human rights violations that may affect the activities of its clients. This Statement is for the financial year ended 31 December 2019. The Board of directors and Chief Executive Officer attest annually that the Group complies with this Statement through the information provided by the corporate social responsibility (CSR), Group Strategic Sourcing and Human Resources Departments respectively.

THE BNP PARIBAS GROUP BNP Paribas is a leading European provider of banking and financial services. It operates in 71 countries and has 198,816 employees.

It holds key positions in its two main businesses: Retail Banking and Services (Domestic Markets and International Financial Services divisions, including areas such as Personal Finance, insurance and Wealth & Asset Management) and Corporate and Institutional Banking (Corporate Banking, Global Markets and Securities Services). Further information is available on BNP Paribas business activities and locations in Chapter 1.4 Presentation of operating divisions and business lines.

Group purchases amount to around EUR 10.6 billion worldwide, spread over nine procurement categories: Banking Services, General Resources, Market Data, Marketing & Communication, Professional Services, Real Estate, Technology, Transaction Fees and Travel.

MODERN SLAVERY AND HUMAN TRAFFICKING RISKS It has been clearly proven by multiple sources (including academic studies, field research and media coverage) that all sectors, industries and regions may be affected to differing degrees by this type of serious breach of human rights.

Therefore, modern slavery risk assessment policies must be regularly updated and must consider a range of factors (including the sector, industry and geographical location of the businesses, products and/or services being analysed), in order to address this complex issue as fully and effectively as possible. Therefore, the risk assessment policy which BNP Paribas uses to address the issues of modern slavery and human trafficking also takes into account the very diverse circumstances of its stakeholders.

Risks linked to BNP Paribas employees

The risks of modern slavery and human trafficking in the Group s operations are deemed to be low. There are no published studies on this topic deeming, a priori, the banking sector and its employees to be particularly exposed to this type of risk, most being highly qualified professionals.

Risks linked to BNP Paribas suppliers

As a banking Group, BNP Paribas manages a supplier portfolio primarily for operational procurement costs, including advice, IT services, safety, IT equipment, furniture and office supplies, promotional items, IT services, consultancy, cleaning, catering and security. The supply chain can be straightforward or extremely complex, based on the expense category. The more complex they are, the greater the human rights-related risks and the difficulties in managing them. According to the procurement risk map which BNP Paribas has introduced, less than a quarter of the Group s procurement categories are high-risk under modern slavery and child labour criteria.

Risks linked to BNP Paribas financing and investment activities

BNP Paribas serves millions of individual customers and professionals, entrepreneurs, small and medium-sized enterprises and large corporate clients in industries with multiple environmental, social and governance (ESG) issues, and operates in countries where legal and governance systems are at diverse levels of development. This diverse backdrop requires highly structured and comprehensive scrutiny and assessment processes which use the expert knowledge of the Group s teams, in order to identify potential modern slavery and human trafficking risks in BNP Paribas customer activities.

BNP PARIBAS POLICY ON MODERN SLAVERY AND HUMAN TRAFFICKING Human rights is one of the pillars on which BNP Paribas CSR strategy is based. The Group is committed to promoting respect for a number of principles and norms which underpin the way it does business:

■ the United Nations Sustainable Development Goals;

■ the 10 Principles of the United Nations Global Compact;

■ the United Nations Guiding Principles on Business and Human Rights;

(1) This Statement applies to all companies within the BNP Paribas Group that are required to have a slavery and modern trafficking statement, except where they have chosen to produce their own statement.

(2) Trafficking in persons is defined as the recruitment, transportation, transfer, harbouring or receipt of persons, by means of a threat or use of force or other forms of coercion, of abduction, of fraud, of deception, of the abuse of power or of a position of vulnerability or of the giving or receiving of payments or benefits to achieve the consent of a person having control over another person, for the purpose of exploitation . United Nations Convention against Transnational Organized Crime and the Protocols Thereto.

(3) Slavery is the status or condition of a person over whom any or all of the powers attaching to the right of ownership are exercised United Nations Slavery Convention.