2018 Registration document and annual fi nancial report - BNP PARIBAS562

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

Any concern about an issue or a suspicion on human rights within the BNP Paribas business operations or in the supply chain can be reported in accordance with the Group whistleblowing procedure, unless local regulations or procedures provide otherwise.

Our whistleblowing policy ensures that action taken in good faith by an employee in connection with the mechanism will not cause the employee to be penalised in any way.

OUR SUPPLIERS BNP Paribas believes that the behaviour of suppliers must also adhere to its commitments on Environmental, Social and G overnance ( ESG ) issues.

Within the Group Procurement Department, the Risks teams and Responsible Procurement teams monitor the CSR risks related to the activities of suppliers and subcontractors. The Group Procurement Department relies in particular on the department s standards and requirements in force which are applicable across the Group and provide for environmental and social criteria to be taken into consideration in the suppliers selection process. In addition, in 2018, the Group s Procurement Department, working with three other French banks, completed an initial version of the environmental and social risk mapping by procurement category initiated in 2017, using a common methodology. Since the autumn of 2018, this mapping has been tested in several BNP Paribas entities.

In addition to the risk identifi cation procedures, the Group has tools to prevent and evaluate environmental, social and governance (ESG) risks:

■ a new supplier CSR charter developed with the same three French banks was published online.

This text sets out the reciprocal commitments of the Group and its suppliers and subcontractors from an environmental and social standpoint and states in particular the obligations specified in the following reference texts:

■ the Universal Declaration of Human Rights of 1948 and its two additional covenants,

■ the 8 Conventions of the International Labour Organization, in particular regarding the minimum age for employment, child labour and abolition of forced and compulsory labour;

■ contractual clauses that require compliance with the conventions of the International Labour Organization were introduced in supplier contract standard templates. These clauses apply in all countries where suppliers are located and are intended to be shared by their own suppliers, subcontractors and distributors;

■ calls for tenders include the CSR assessment of suppliers and subcontractors, with the deployment of a sustainability questionnaire that includes specifi c clauses on environment, ethics and human rights.

OUR BANKING AND FINANCIAL ACTIVITIES BNP Paribas serves millions of individual customers and professionals, entrepreneurs, small and medium-sized enterprises and large corporate clients in industries with multiple ESG issues, and operates in countries where legal and governance systems are at diverse levels of development. BNP Paribas strives to reduce potential violation of social and environmental rights, including human rights, from its fi nancing and investment activities. Its ESG risk management system(1) is Group-wide and based on:

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

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

■ the development of fi nancing and investment policies managing the Group s activities in sectors with signifi cant ESG issues;

■ the implementation of a specifi c ESG risk assessment framework for its products and services.

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). Aimed at employees of EDH member companies, this module is included in the BNP Paribas training catalogue, accessible to all employees. It is mandatory for all employees who directly contribute to the promotion of human rights: Risk people, Procurement business lines, business relations offi cers in CIB and the CSR network.

This initiative is monitored by one of the thirteen managing indicators of the BNP Paribas CSR strategy: the percentage of employees contributing directly to the promotion of human rights who have received a specifi c training . This indicator is also one of the nine CSR indicators used in calculating the deferred variable compensation of the Group s 6,750 key employees. These nine indicators account for 20% of the conditions for attributing this compensation.

(1) For more information, refer to the Group s 2018 Registration document, Commitment 3, Systematic integration and management of environmental, social and governance risks; Commitment 8, Combat social exclusion and promote respect for human rights; and chapter 7.6, Duty of care: 2018 BNP Paribas' vigilance plan.

Jean-Laurent BONNAFÉ Director and Chief Executive Offi cer

Jean LEMIERRE Chairman of the Board of D irectors

February 28, 2019