70FIGHT CORRUPTION AND TAX EVASION

20 19 N FR

Country risk

To manage country risks, especially risks of corruption and the fight against money laundering, we have drawn up lists that allow us to better exercise due diligence when we enter into new business relationships with clients or when we carry out client transactions.

These lists are principally drawn up on the basis of two criteria:

→ Mandatory use of official country lists: List of countries under sanctions from the German or French finance ministries, European Union and United Nations lists, etc.

→ Non-mandatory use of the ratings by two independent institutions, namely:

Transparency international

This independent institution establishes a rating of each country using criteria principally based on corruption indices.

www.transparency.org

Know your Country

This database also provides a rating and a report for each country, principally founded on anti-money laundering criteria (including tax fraud).

www.knowyourcountry.com

These official country lists, together with ratings by independent agencies whose use is not mandatory and solely results from the Group s internal process allow us to draw up three country lists that correspond to three distinct levels of vigilance.

The higher the risk, the greater the level of vigilance. The application of these lists can also result in refusal to enter into a new business relationship. In most cases, this refusal will be coupled with other criteria used in our risk matrices (activities undertaken, amounts involved, origin of funds and persons under sanctions). This analysis is performed for the riskiest cases by the Group s compliance teams.

These lists are regularly updated to reflect changes in official lists and ratings by independent agencies.