2018 Registration document and annual fi nancial report - BNP PARIBAS522

7 A COMMITTED BANK: INFORMATION CONCERNING THE ECONOMIC, SOCIAL, CIVIC AND ENVIRONMENTAL RESPONSIBILITY OF BNP PARIBAS

7

Our economic responsibility: fi nancing the economy in an ethical manner

In 2018, the Ethics Committee discussed the concept of corporate raison d'être or purpose and expressed opinions on the recommendations of the Sénard-Notat report and the Label B Corporation offered by B Lab. A detailed presentation of the Group s strategy in terms of corporate commitment was also made. The following issues were also brought to the Committee s attention: the Group s business in Turkey, the implementation of the GDPR (General Data Protection Regulation) regulations and the Group s data protection policy, the implementation of the French laws on the duty of care of multinationals and anti-corruption (Sapin 2). The members of the Ethics Committee were also consulted and gave their opinion on the criteria applied by the Group in terms of the fi nancing of light fi rearms in the United States and the healthcare sector. Lastly, the members discussed the record of their work since the Committee s fi rst meeting in July 2015 and made recommendations for the future.

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 has been updated in order to meet regulatory requirements: Sapin 2 law (protection of whistle-blowers and provisions for the fi ght against corruption), MiFID II, the duty of care law . The update of this procedure enabled the whistleblowing system to be consolidated by strengthening the protection for whistle-blowers, in particular thanks to an offi cial appointment process for Whistleblowing contacts, and the drafting of specifi c rules on confi dentiality.

The fi ght against corruption and money laundering

In terms of fi nancial 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 defi ned in 2017 continued throughout the Group, with the effective implementation expected 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 law of 9 December 2015 on transparency, anti-corruption and modernising the economy. This anti-corruption system, which was incorporated into the BNP Paribas C ode of c onduct in 2018 is built around governance, corruption risk mapping, policies, procedures and tools used to control identifi ed risks, internal alert systems, and fi nally, controls and reports.

The measures undertaken enabled the existing system to be strengthened in 2018 to comply with new recommendations from the Agence Française Anti-Corruption (French Anti-Corruption Agency AFA). Anti-corruption contacts were appointed at all operational levels of BNP Paribas and the Central team was expanded, the internal alert system and the corruption risk mapping were considerably improved and an e-learning awareness raising training module on the risks of corruption was launched for all employees. These measures will be supplemented in 2019 in particular by reinforcing operational accounting controls and the 1st and 2nd level controls of the anti-corruption system.

Training

At end 2018, 96.2% of the 184,312 employees concerned had taken online training on international sanctions and embargoes, while 93.1% of the 185,086 employees concerned received anti-money laundering and fi nancing of terrorism training.

Regarding competition law, 91.5% of the Group s employees (non-exempt) passed the competition law and you training at the end of 2018.

Finally, 89% of the Group s 195,133 employees attended the Know Your Data (KYD) course this year and 87% of the employees in the European Economic Area passed the Personal Data Protection training course.

The fi ght against tax evasion

The amount of taxes and duties due by the Group stood at EUR 5.6 billion in 2018, 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: net banking income, headcount, results, taxes paid. It is clear from the data that the location of its offi ces 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 of the Registration document).

To this end, BNP Paribas ensures that its entities do not benefi t unduly from privileged tax schemes. Moreover, the Group avoids locations in States or territories considered uncooperative by France or the offi cial 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 fi ll 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.