574 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

■ the internationally-accepted OECD Guidelines for multinational enterprises;

■ the internationally-accepted standards of human rights, as defined in the International Bill of Human Rights;

■ the core labour standards set out by the International Labour Organisation.

These public commitments are supported by internal Group Policies, which contribute to tackling numerous subjects on social, environmental and governance issues, including human rights violations. These 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 effective identification of modern slavery practices through specific policies and processes is the first step towards preventing, mitigating and redressing these practices. BNP Paribas has therefore taken the following measures in order to exercise its duty of care in this area with the required degree of seriousness.

BNP Paribas employees

BNP Paribas commits to offer a working environment in which all employees are treated fairly. In particular, the Group focuses on respect, the need to apply the most stringent norms of professional behaviour and rejects all forms of discrimination. BNP Paribas implements a number of policies in this area, including an annual review of high-risk countries in terms of human rights, and monitoring of employees aged between 16 and 18 (in 2019 there were three: one in Brazil, one in the United States and one in the United Kingdom). The existing Group s permanent policies and procedures notably include the Diversity and Inclusion policy, and the remuneration principles which reaffirm the non-discrimination principle in the recruitment process and professional development of employees. The BNP Paribas Code of conduct, whose rules must be understood and followed by all employees, confirms the Group s commitment against harassment, including sexual harassment.

On this basis, everyone within the Group has the responsibility to treat all colleagues with respect, ensure that interactions with colleagues are professional and effective at all times, and listen to and value input from colleagues, even if they express different views.

The agreement on fundamental rights and the implementation of a global social framework, signed on 18 September 2018, has implemented an ambitious system which contributes to improving quality of life and working conditions for employees, thereby helping to promote a more equal society and inclusive growth.

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

Raising concerns 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 organisational superior, but also, alternatively, to the compliance team of the entity to which they belong, or of a higher level. 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.

Consequently, 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.

BNP Paribas suppliers

Dedicated teams in Group Strategic Sourcing deal with supplier-related ESG risks.

BNP Paribas bases its ESG risk management system for its suppliers and subcontractors on the following elements:

■ an ESG risk map covering 13 issues, including modern slavery and child labour, 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;

■ contractual clauses incorporating compliance with the conventions of the International Labour Organization were introduced in all countries in which suppliers operate, including the option of ending contracts if suppliers do not comply with the Group s ESG requirements;

■ ESG questionnaire templates used for calls for tenders, which include specific questions on the environment, ethics and human rights.

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

■ training for the Sourcing business.

For BNP Paribas clients (financing and investment activities)

BNP Paribas has set up ESG risk management systems for its financing and investment activities (see also Rigorous management of Environmental, Social and Governance (ESG) risks, Commitment 3). These systems are based on:

■ the development of financing and investment policies to regulate sectors with high ESG risks;

■ respect for the Equator Principles for major industrial and infrastructure projects;

■ the integration of ESG criteria into the Know Your Customer process (KYC);

■ a progressive integration of ESG criteria into lending and rating policies;