Société Générale / Risk report 2021 - Pillar 3 2020

13 COMPLIANCE RISK, LITIGATION COMPLIANCE | SOCIETE GENERALE GROUP | PILLAR 3 - 2021 219 Lastly, the Group has implemented the new European Directive on transparency between intermediaries (referred to as DAC 6), which will require the reporting of cross-border tax arrangements. The Group Compliance Division has supported the Group Tax Department in implementing DAC6, more specifically the D regulatory marker regarding schemes aimed at circumventing the CRS and those involving opaque chains of beneficial owners. The first reports are expected to be filed after 31 January 2021. Importantly, the account-keeping entities of the Private Banking business line are established exclusively in countries with the strictest tax transparency rules imposed by G20 member countries and the OECD. These countries ratified the Convention on Mutual Administrative Assistance in Tax Matters, introduced the automatic exchange of information in financial accounts (CRS) and obtained the “largely compliant” and “compliant” rating as part of the peer review process conducted under the aegis of the OECD. Assets deposited in Private Banking books are subject to enhanced scrutiny using comprehensive due diligence procedures to ensure they are tax compliant. In accordance with regulatory requirements, Societe Generale also includes tax fraud in its antimoney laundering procedures. ANTI-CORRUPTION MEASURES Societe Generale is fully committed to fighting corruption and has given clear undertakings in this respect by participating in the Wolfsberg Group and the Global Compact. The Group applies strict principles that are included in its Code of Conduct and its “Anti-Corruption and Influence Peddling Code”. Societe Generale’s anti-corruption programme is built around the following themes: Code of Conduct; p annual risk mapping; p appropriate training at all levels (senior management, exposed p persons, all employees); control systems; p accounting procedures; p evaluation of third parties; p disciplinary system; p right to whistleblow. p Within this context, processes and tools continue to be strengthened with the provision of staff dedicated to anti-corruption practices within the Group, and the creation of monitoring indicators and new controls - including accounting and operational controls to reduce the risk of corruption. The Group’s anti-corruption instructions have been greatly expanded. Accordingly, the Anti-Corruption and Influence Peddling Code has been updated and supplemented. Furthermore, several instructions and procedures have been published or updated this year, thereby constituting a thorough and updated body of instructions. The implementation of certain instructions was accompanied by the establishment of Group tools, such as the tool for declaring gifts and invitations (GEMS), the tool for whistleblowing management (WhistleB, now available Group-wide), and the annual conflict of interest declaration tool (DACI). controllers, and members of General Management and the Board of Directors. Training measures have been strengthened, in particular with respect to persons most exposed to the risk of corruption, accounting Third-party knowledge procedures have been improved, with special focus on intermediaries, as well as the introduction of due diligence for suppliers and associations benefiting from donations or sponsorship initiatives. The ABC (Anti-Corruption) function now plays an active role in developing KYC (Know Your Customer) processes in the bank’s Global Banking business. A comprehensive training programme is being rolled out to increase the vigilance of employees. The programme was reinforced throughout the Group in 2020 resulting in the following: e-learning for all staff: an enhanced version of this training p programme was put online in July 2020 (99% completion rate); training dedicated to employees most exposed to the risk of p corruption (98% completion rate) and to employees in charge of accounting and in charge of accounting and financial controls (418 people trained in webex); anti-corruption experts as well as members of the ABC network have p completed a diploma course (ACAMS). CORPORATE SOCIAL RESPONSIBILITY In keeping with the Group’s strategic ambitions, a dedicated team in the Compliance Division is now responsible for Corporate Social Responsibility as the second line of defence. In particular, it oversees the project targeting compliance with the ESG (1) Directive aimed at promoting sustainable investment and strengthening the transparency of ESG investment products and services provided to customers In 2021, efforts will also be made towards the operational implementation of the Bank’s social and environmental commitments by systematically checking exclusion and identification lists, as well as taking sectoral policies into consideration in the onboarding and customer review process. Lastly, there are plans to develop appropriate training courses for affected categories of staff. DATA PROTECTION As a trusted partner of its customers, Societe Generale is especially sensitive to personal data protection. The entry into force, in May 2018, of the new European General Data Protection Regulation (GDPR), which increases the Company’s obligations and the level of sanctions in case of non-compliance with these obligations (up to 4% of revenue) has offered an opportunity for the Group and its subsidiaries to further reinforce their compliance system. Across all Group entities, internal instructions and associated procedures in line with local and European regulations define the rules to apply and the measures to take to guarantee the protection and security of customer and staff data. Measures to inform data subjects and process their demands are in place so that such persons can exercise their rights, notably by way of dedicated digital platforms. A personal data security policy has been defined, which fits in with the Group’s overall security strategy, especially as regards cybersecurity. Moreover, as part of GDPR deployment, there has been a specific effort to increase staff awareness through dedicated training. An e-learning module has been introduced for the employees of every entity concerned. At end-2020, 98.5% of employees had undertaken the training. Environment, Social and Governance. (1)