Managing legal, regulatory or ethical risks

Professional ethics

Professional ethics form an integral part of our compliance system, the main principles of which are laid down by BPCE and subsequently implemented by each Group entity according to the specific nature of its activities. Compliance with the rules of good conduct by employees enables each entity to pursue its activities in an honest, fair and professional manner, and to serve its customers’ best interests.

Our Group has drawn up a Code of Conduct and Ethical Standards to ensure that we act in the best interests of our customers, employees, and society as a whole.  

We have set up a mechanism for monitoring and managing the disclosure of confidential and privileged information. Respect for bank secrecy or professional secrecy is a principle that brooks no exceptions. Confidential, i.e. non-public, information about a customer or company is subject to special monitoring. As the Group owns several listed subsidiaries, procedures for monitoring and controlling privileged information have been put in place. Special provisions have been made to cover securities transactions on the Group or non-Group listed companies carried out by employees enjoying access to privileged information on a permanent or occasional basis.

The continuous drive to train and sensitize our employees to the need to respect ethical rules in the exercise of their functions is of vital importance. The Group has been running a professional certification system for several years that enables it to verify that actions related to the presentation, recommendation, and sale of financial products and services to customers are carried out by staff possessing the appropriate professional qualifications.

The fight against corruption and influence peddling

We are committed to fighting against all forms of corruption, including influence peddling and facilitating payments. This commitment finds concrete expression in our adoption of anti-corruption rules of conduct that comply with the requirements of the French law dated December 9, 2016 on transparency, the fight against corruption and the modernization of economic life (the so-called “Sapin 2” law). These rules concern all Group employees and require them to remain vigilant in situations involving risk. These risk situations have been identified in a mapping exercise. Failure to comply with these rules may lead to disciplinary action. The prevention of corruption is also encouraged by the compulsory completion of an e-learning course that includes practical case studies.

Financial security

We are engaged in the prevention of financial crimes, which includes the fight against money laundering and the financing of terrorism, but also the respect of the sanctions against certain countries, persons or entities decided by France, the European Union, the United States or the UN, and any other applicable regulations given the geography of the Group’s business presence.

All of our companies ensure compliance with the principles and rules laid down in relevant legislation in accordance with the standards defined, in particular, by the FATF¹, the United Nations or EU institutions².

The principles and frameworks are defined by BPCE and are applied by all of its entities. The operational teams are regularly sensitized to issues related to financial security, whether new forms of financial crime or legislative and regulatory developments in this area; dedicated training materials are used by all Groupe BPCE employees.

The prevention of money laundering and the financing of terrorist activities is based on the principle of ‘Know Your Customer’ complemented by constant vigilance exercised with regard to financial activities, calling on the assistance of the retail banking networks as well as the Group employees directly assigned to the management of these issues.

^{1- FATF, or the Financial Action Task Force (FATF), leads the global effort to combat money laundering and the financing of terrorism and the proliferation of these activities.      2- Directives and regulations issued by the European Commission or the Council of the EU.}

Business continuity

Like any business organization, Groupe BPCE companies may be affected by events or crises serious enough to affect the smooth running of their organization and, consequently, the quality of the services provided. In such circumstances, the teams in charge of business continuity identify and validate alternative solutions to be implemented with a view to:
•    Reducing exposure to certain events or disasters,
•    Managing crisis situations and limiting the impact of losses,
•    Ensuring that the essential activities of Groupe BPCE’s companies resume as quickly as possible,
•    Maintaining a minimum level of service by all available means,
•    Restoring a normal operating mode as soon as possible.

All financial institutions in the Group, and the structures contributing to the pursuit of financial activities, have developed a continuity mechanism that can be activated, notably in the event of a major disaster.
All our employees are involved to varying degrees and are liable to participate in the implementation of continuity solutions. These solutions are derived from previously identified loss scenarios and their validity is ensured by a recurrent test policy involving the active participation of the Group’s employees, by regular controls, and by a periodic review of continuity requirements, available resources, and related procedures.