2018 Registration document and annual fi nancial report - BNP PARIBAS 559
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
The European social charter from which derives the European agreement on the prevention of stress at work, applied since 2017, the programmes related to the prevention of psychosocial risks and stress at work, commitment on maternity/paternity, the charter on the balance of professional life and personal life in France, the principles of performance evaluation and new ways of working contribute to a better balance of work patterns.
BNP Paribas has 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 specifi cities 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 Within the Group Procurement Department, a structure dedicated to Responsible Procurement based on a network of around 50 correspondents covers all CSR topics, including CSR risks related to the activities of tier 1 suppliers and sub-contractors.
In 2018, the Group Procurement Department completed, with three other French banks, an initial version of the risk mapping initiated in 2017, using a common methodology developed with an external service provider. Since the autumn of 2018, this mapping has been tested by several BNP Paribas entities for gradual deployment in various countries starting in the second half of 2019.
In addition to the risk identifi cation procedures, the Group has tools to prevent and evaluate ESG risks:
■ a new Sustainable Sourcing Charter charter drafted jointly with three other French banks was published on the Group s website in March 2018 and made available to the Procurement teams. This new Group Charter completes existing charters adapted to local conditions. It includes both the commitments of the signatories to their suppliers and the commitments expected from suppliers in terms of ethics, human rights, respect for the environment and progress, including with regard to subcontractors. A total of nearly 1,000 supplier charters were signed in 2018 or included in contracts signed by suppliers;
■ contractual clauses incorporating or completing expectations in terms of environmental and social criteria were communicated in the Sustainable Sourcing Charter;
■ in 2018, the human rights training requirement was extended to the middle and back offi ces of the Procurement teams. In this extended scope, more than 70% of the employees concerned were trained, as were more than 85% of Procurement teams at head offi ce level . This requirement will be renewed in 2019 as part of the progress initiative in partnership with human resources;
■ 2,300 CSR assessments of suppliers and sub-contractors were conducted in 2018 as part of requests for proposal , in particular those
relating to categories of risky purchases, such as printing equipment or promotional items;
■ the deployment of specific questionnaires continues. They were developed by the Responsible Procurement team at the request of buyers in connection with the ESG risks highlighted by the new mapping.
The use of CSR evaluation questionnaires in requests for proposal and the inclusion of their results in the overall evaluation of the supplier are included in the Group Procurement Department s operational control plan.
In France, BNP Paribas is a signatory to the Responsible Supplier Relations Charter promoted by the Business Mediation body of the French Ministry of the Economy and Finance, which notably offers recourse to an independent internal mediator.
For its Annual Procurement Morning in June 2018, the Procurement Department, in conjunction with the Group s Legal Function , presented a hundred of suppliers with an update on regulatory developments and their implications, including the duty of care.
OUR BANKING AND FINANCIAL ACTIVITIES
The distribution of fi nancial products and services
The Group has identifi ed two main risks in the distribution of its products and services for individuals: non-discrimination in the access to fi nancial services and the right to privacy (protection of customers personal data).
To reduce the risk of discrimination in the access to fi nancial services, the Group implements a fi nancial inclusion approach, by supporting microfi nance through fi nancing and services provided to specialised institutions, by improving access to credit and insurance, and by supporting clients facing diffi culties as a result of their disability or their fi nancial situation. In addition to regulatory requirements in relation to the Duty of care, the Group has launched several initiatives that fall under its CSR commitment No. 7 on Products and services that are widely accessible .
Moreover, as part of its general policy on managing personal data, BNP Paribas intends to use the best data protection systems available in all the entities and countries where the Group is present. In 2017, BNP Paribas began to change its current system to address all the requirements of the new European General Data Protection Regulation (GDPR).
Financing and investment activities
The activities of BNP Paribas customers may involve risks in relation to human rights and fundamental freedoms, human health and safety, and the environment. At the end of 2018, the Group published Responsible Business Principles for its customers, thus reaffi rming BNP Paribas s expectation to engage with customers whose business practices demonstrate a high level of governance and responsibility with respect to human rights, fundamental freedoms, human health and safety, and the environment.
