2018 Registration document and annual fi nancial report - BNP PARIBAS558

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 traffi cking statement

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 C ode 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.

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.

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 (Procurement ) 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 traffi cking, 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.

Systems used to manage these risks

The Group has taken stock of its existing systems and analysed them in view of the elements required to develop the vigilance plan.

In 2017, an inventory of ESG risks analysis tools (such as HR, procurement and credit policies) was conducted for the entire group. This inventory was compared against the requirements of the law regarding the preparation of the vigilance plan. This comparison made it possible to ensure that the main risks were effectively covered by the existing systems for employees, suppliers and banking and fi nancial activities.

In 2018, BNP Paribas fi nalised its risk mappings for its banking and fi nancial activities and the activities of the suppliers and subcontractors with which the Group has commercial relationships.

Action plans have been defi ned by scope to complete the existing risk prevention systems . These action plans are monitored by the heads of the relevant businesses and functions, who are members of the Group Executive Committee.

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.

The review conducted in 2017 and 2018 by BNP Paribas made it possible to ensure adequate coverage of all salient risks as well as their formalisation in the pre-existing Group HR policies.

The Group s diversity policy and remuneration principles reaffirm the principle of non-discrimination in the recruitment and career 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 specifi c 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. The agreement on fundamental rights and global social framework (Global agreement ) signed in September 2018 with UNI Global Union, the International Trade Union Federation of the service sector, aims to implementing in each entity in the countries where the Group operates, at least one of the 10 commitments of the ILO Enterprise and Disability Charter. At the end of 2018, 91% of entities with more than 1,000 employees already made such a commitment. The objective included in the criteria of the medium-term incentive plan of 6,750 key employees is to reach 95% in 2020;

■ 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. For example, a goal of at least 40% women in the Graduate & Talent programmes of the market activities will be pursued by 2020. At the end of 2018, women represented 28% of the Group s Senior Management Position (SMP) population. The target of 30% was included in the medium-term incentive plan criteria of 6,750 key employees for the period 2018-2020 (see Our social responsibility: developing and engaging our people responsibly, chapter 7.3).

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 C ode of conduct in 2016 strengthens the Group s commitment to combating harassment, including sexual harassment. The HR Function also introduced an internal procedure 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.