20 19 NFR

69FIGHT CORRUPTION AND TAX EVASION

The principal risks associated with the activities of a bank specialising in investment services are well known. To limit exposure to these risks as far as possible, our main objectives are to:

→ Comply with rules protecting the integrity of financial markets and avoid all situations that could lead to market abuse (inside information and price manipulation)

→ Fight money laundering (including fraud and tax evasion) and the financing of terrorism

→ Protect our clients interests by offering them investment services and financial instruments that are appropriate for their understanding of risks, their envisaged investment horizon and their investment objectives

→ Establish a mechanism for fighting corruption, which in particular:

Identifies the most critical situations by mapping them out

Makes it possible to monitor conflicts of interests

Sets out a clear procedure for commencing new business relationships with our clients and our principal service providers (through a system that identifies country risks, including corruption risks)

Includes an early-warning mechanism

APPROACH AND METHODOLOGY

Within the ODDO BHF Group, we have a very extensive body of rules covering all the aforementioned risks.

These rules can be accessed by all employees on the Group s intranet and are updated regularly to take into account constant changes to the regulations applicable to us.

Group employees receive regular training to ensure they understand these rules correctly. In most cases, training is focused on the key risks for the business line in question.

Lastly, activities are monitored by independent teams to identify any violations of regulations or internal rules. The results of these controls are shared with the business lines and management in order to improve our practices and continue limiting non-compliance risks.