BPCE SA

France|Banks|FY2025|Auditor: PricewaterhouseCoopers Audit and Forvis Mazars SA|View original report →

Sustainability statement, in full

The complete text of BPCE SA’s FY2025 sustainability statement is held here – 387 pages, captured from the published report. Every disclosure below also links to its own passage.

ESRS 2 – General Disclosures

GOV-1The role of the administrative, management and supervisory bodies
Reported

Reference: page 337 (BPCE's sustainability report, cross-reference); page 71 (Groupe BPCE's sustainability report).

BPCE's own statement, heading 1.4.1 "(GOV-1) Role of the administrative, management and supervisory bodies", reads in full: "See the corresponding section in Groupe BPCE's sustainability report" (p.337).

The substance sits in Groupe BPCE's report: the Supervisory Board "supervises and provides perspective on, the group's ESG strategy", while "the Executive Management Committee of Groupe BPCE validates the ESG strategy, ensures its implementation and oversees the group's risk management" (p.73). Dedicated bodies include the Audit and Investment Committee, the Cooperative and CSR Committee and the Risk Committee at Supervisory Board level, and the ESG Risk Committee, the Environmental Transition Strategy Committee, the ESG Data Strategy Committee and the Group Regulatory Monitoring Committee at executive level (pp.73-75).

GOV-2Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies
Reported

Reference: page 337 (BPCE's sustainability report, cross-reference); pages 73-76 (Groupe BPCE's sustainability report).

BPCE's heading 1.4.2.1 "Sustainability topics addressed by the administrative, management and supervisory bodies" states only: "See the corresponding section in Groupe BPCE's sustainability report" (p.337).

Groupe BPCE's own account lists, for each governing body, its chairman, meeting frequency and the "Main ESG topics addressed in 2025": the Audit and Investment Committee (12 meetings/year) reviewed "the double materiality assessment approach followed, results of the exercise and guidelines adopted"; the Risk Committee (12 meetings/year) covered "Climate scenarios and stress test approach" and "Climate and Environmental Risk Management (RAF)" (pp.73-75). "The double materiality assessment was presented to the Cooperative and CSR Committee on November 27, 2025 and to the Audit and Investment Committee on December 9, 2025" (p.75).

GOV-2(was GOV-3)Integration of sustainability-related performance in incentive schemes
Reported

Reference: page 337 (BPCE's sustainability report, cross-reference); page 76 (Groupe BPCE's sustainability report).

BPCE's heading 1.4.3 "(GOV-3) Integration of sustainability-related performance in incentive schemes" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.337).

Groupe BPCE's text: "On February 6, 2025, on the proposal of the Remuneration Committee, BPCE's Supervisory Board decided to set the Management Board's variable pay targets for the 2025 fiscal year by incorporating a specific criterion related to the environment, climate and decarbonization trajectories with a weighting of 5%." For 2026, "the portion of qualitative objectives in the annual variable pay of the Chairman of the Management Board is 40%", of which the climate-linked common objectives carry "a weight of 5% within the 40%" (p.76).

GOV-3(was GOV-4)Statement on due diligence
Reported

Reference: page 338 (BPCE's sustainability report, cross-reference); page 80 (Groupe BPCE's sustainability report).

BPCE's heading 1.4.5 "(GOV-4) Statement on due diligence" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.338).

Groupe BPCE's own GOV-4 is a concordance table mapping the "Core elements of due diligence" to the sections of the statement: "a) Embedding due diligence in governance, strategy and business model" maps to sections 1.3.1.1/1.3.1.2/1.4.2; "c) Identifying and assessing adverse impacts" to 1.3.2; "d) Taking actions to address those adverse impacts" to 1.5.1/2.2.2.1 and further topical sections; "e) Tracking the effectiveness of these efforts and communicating" to 2.2.3.10/2.2.4.1/3.2.4.1/3.4.4.1 (p.80).

GOV-4(was GOV-5)Risk management and internal controls over sustainability reporting
Reported

Reference: page 338 (BPCE's sustainability report, cross-reference); pages 77-78 (Groupe BPCE's sustainability report).

BPCE's heading 1.4.4 "(GOV-5) Risk management and internal controls over sustainability reporting" reads, for both of its sub-points (main features of the risk management system, and main features of ESG risk management): "See the corresponding section in Groupe BPCE's sustainability report" (p.338).

Groupe BPCE's text: "In its capacity as the central institution, BPCE also monitors the correct application of group rules by required entities and validates their compliance with these rules. Within the group, the entities subject to the requirement to publish a sustainability report in 2025 are Natixis SA, BRED Banque Populaire and Banque Palatine" (p.77). A dedicated "Responsible Finance Steering (PFR)" unit within the group Finance department coordinates institutions' work on the report, alongside the Impact department, which leads CSRD acculturation sessions and shares responsibility for the double materiality rating with the ESG Risk department (p.78).

SBM-1Strategy, business model and value chain
Reported

Reference: pages 336-337 (BPCE's sustainability report, cross-reference); pages 61-68 (Groupe BPCE's sustainability report).

BPCE's heading 1.3.1 "(SBM-1) Strategy, business model and value chain" and each of its seven sub-points (sustainability-related strategy, targets, business model, major product/client groups, prohibited products, commitments, value chain) all read: "See the corresponding section in Groupe BPCE's sustainability report" (pp.336-337).

Groupe BPCE's text: "In 2024, Groupe BPCE rolled out its strategic project VISION 2030, a growth project at the service of its clients... The priority given to the climate in its latest strategic project has been renewed and integrated into the Impact strategy, with non-financial [performance] comprised of fifteen key impact indicators" (p.61). BPCE SA is the central institution of the group, alongside the Banque Populaire and Caisse d'Epargne networks, Natixis SA, Banque Palatine and Oney (p.54 org chart).

SBM-2Interests and views of stakeholders
Reported

Reference: page 337 (BPCE's sustainability report, cross-reference); page 69 (Groupe BPCE's sustainability report).

BPCE's heading 1.3.2 "(SBM-2) Interests and views of stakeholders" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.337).

Groupe BPCE's text: "The group's cooperative model places dialogue with stakeholders at the heart of its actions... By holding the company's capital through cooperative shares, customers become cooperative shareholders and actively participate in the life strategy" (p.69). A stakeholder-dialogue table tags each group (cooperative shareholders, Board members, employees, clients) against the topical standard it relates to, e.g. "Employees [S1]" and "Clients [E1, S3, S4]" (p.69).

SBM-3Material impacts, risks and opportunities and their interaction with strategy and business model
Reported

Reference: page 338 (BPCE's sustainability report, cross-reference); pages 94-95 (Groupe BPCE's sustainability report).

BPCE's heading 1.5.3 "(SBM-3) Material impacts, risks and opportunities and their interaction with the group's strategy and business model" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.338).

The interaction with strategy is carried through summary tables the Group publishes per topic linking "material IROs and policies, actions, metrics and targets" (e.g. p.185 for S3, p.196 for S4), and the governance note that "the material impacts, risks and opportunities (IROs) focus on: climate change, own workers, affected communities, consumers and end-users and business conduct" (p.75).

IRO-1Description of the processes to identify and assess material impacts, risks and opportunities
Reported

Reference: page 338 (BPCE's sustainability report, cross-reference); pages 81-93 (Groupe BPCE's sustainability report).

BPCE's heading 1.5.1 "(IRO-1) Impact, risk and opportunity management" and its five sub-points (methodology, rating methodology, stakeholder consultation, governance, review process) all read: "See the corresponding section in Groupe BPCE's sustainability report" (p.338).

Groupe BPCE's text: "The double materiality exercise is the starting point for the preparation of the sustainability report" (p.81). The Impact department rates impacts and opportunities while the ESG Risk department rates risks (p.90). "In 2025, the materiality of physical and transition environmental risks was assessed at level 1 out of 3 ('significant') for Groupe BPCE, while the materiality of social and governance risks was assessed at a level of 0 out of 3 ('low')" (p.86).

IRO-2Disclosure requirements in ESRS covered by the undertaking's sustainability statement
Reported

Reference: page 371 (BPCE's sustainability report, cross-reference); page 222 (Groupe BPCE's sustainability report).

BPCE's own Part 5 Appendix, heading 5.1 "[IRO-2] Disclosure Requirements in ESRS covered by the undertaking's sustainability report", states in full: "See the corresponding section in Groupe BPCE's sustainability report" (p.371). BPCE SA prints no concordance table of its own.

Groupe BPCE's own IRO-2 table (p.222) is the formal concordance used for this file's classification; it does not list E1-5, E1-7, E1-8, E1-9, the S2 topic, or G1-5 among the disclosure requirements it covers, and explains: "All mandatory and material data points are disclosed with the exception of data points that are unsuitable for the Group's activities" (p.221).

E1 – Climate Change

E1-1Transition plan for climate change mitigation
Reported

Reference: pages 339-340 (BPCE's sustainability report, cross-reference); pages 104-105, 119 (Groupe BPCE's sustainability report).

BPCE's headings 2.2.1.2 "(E1-1) Transition plan for climate change mitigation" and 2.2.2.1 "(E1-1-16(i)) Approval of the transition plan..." both read: "See the corresponding section in Groupe BPCE's sustainability report" (p.340).

Groupe BPCE's text: "In 2024, with the VISION 2030 strategic project, Groupe BPCE committed to long-term action" (p.104). The plan "comprising the guidelines presented in 2.2.1.2... was approved on March 3, 2026 by the Management Board, then by the Supervisory Board, which took note of it" (p.105), with the Environmental Transition Strategy Committee, chaired by the Chairman of the Management Board, validating the guidelines beforehand.

E1-2(was covered under ESRS 2 IRO-1)Identification of climate-related risks and scenario analysis
Reported

Reference: pages 86-87 (Groupe BPCE's sustainability report).

Back-filled from ESRS 2 IRO-1, where this content is disclosed in the FY2025 report, since E1-2 (Identification of climate-related risks and scenario analysis) did not exist as a numbered disclosure requirement under the 2023 ESRS the report was prepared against. BPCE's own statement incorporates the group-level analysis by cross-reference (Introductory remarks, p.335).

"Groupe BPCE mainly relies on the SSP2-4.5 scenario (IPCC) and Nationally Determined Contributions scenario (NGFS) to define a median trend for risk monitoring purposes. For its risk assessment purposes in a deteriorated context, in stress test exercises for example, Groupe BPCE also relies on alternative, more extreme scenarios: SSP5-8.5 scenario (IPCC) on physical risk and Net Zero 2050 and Delayed Transition scenarios... on transition risk" (p.87). Scenarios come from the IPCC, NGFS and IEA and are "validated at the executive management level" (p.86).

E1-3(was covered under ESRS 2 SBM-3)Resilience in relation to climate change
Reported

Reference: pages 128-129 (Groupe BPCE's sustainability report).

Back-filled from ESRS 2 SBM-3, where resilience is disclosed in the FY2025 report under heading 2.2.6.2 "(ESRS 2 SBM-3) Strategy and Business Model Resilience", since E1-3 (Resilience in relation to climate change) did not exist as a numbered disclosure requirement under the 2023 ESRS. BPCE's own statement incorporates this by cross-reference (Introductory remarks, p.335).

"Groupe BPCE analyses the resilience of its business model across its three activities (financing, insurances, asset management) through climate stress tests as part of the self-assessment process of its capital (ICAAP) and liquidity (ILAAP)" (p.128), using a heat-wave hazard "based on the 99th percentile of the NGFS scenario" and "the NGFS Net Zero 2050 scenario" for transition risk. Conclusion: "the material risks identified... do not call into question the resilience of Groupe BPCE's business model over the time horizon of its strategic plan" (p.129).

E1-4(was E1-2)Policies related to climate change mitigation and adaptation
Reported

Reference: page 341 (BPCE's sustainability report, cross-reference); pages 106-107 (Groupe BPCE's sustainability report).

BPCE's heading 2.2.3 "(E1-2) Policies related to climate change mitigation and adaptation" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.341).

Groupe BPCE discloses two ESG sector policies with climate content: on thermal coal, a 2021 "commitment to reducing its financial exposure to thermal coal to zero by 2030 for the European Union and OECD countries, and by 2040 for the rest of the world" (updated March 2025); and on oil and gas, a commitment "to reducing its financed carbon emissions related to the end-use of oil and gas extraction and production between 2020 and 2030" referencing the IEA's Net Zero Emissions by 2050 scenario. Both policies apply to "the banking and financial activities of the Banque Populaire and Caisse d'Epargne networks, BPCE SA and Natixis SA" (pp.106-107).

E1-5(was E1-3)Actions and resources in relation to climate change policies
Reported

Reference: page 343 (BPCE's sustainability report, cross-reference); pages 108-110 (Groupe BPCE's sustainability report).

BPCE's heading 2.2.4.1 "(E1-1-16(b)) Description of decarbonization levers and key actions" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.343).

Groupe BPCE's own-footprint reduction rests on "four action levers: Real estate... Purchasing... Mobility... Digital" (p.109). Concrete 2025 actions include two 20-year Power Purchase Agreements (with Opale and H2air) that "will cover 30% of the group's annual consumption" from January 2026; the "Achats 2030" consortium of roughly 30 players to decarbonize bancassurance purchasing; and the Real Estate Master Plan, under which "the building stock will emit around 8% less carbon by the end of 2026 compared to 2023" (pp.109-110). Twelve institutions are "committed to the full electrification of their fleet by 2030 at the latest" (p.110).

E1-6(was E1-4)Targets related to climate change mitigation and adaptation
Omitted
E1-7(was E1-5)Energy consumption and mix
Not Material
E1-8(was E1-6)Gross Scopes 1, 2, 3 and Total GHG emissions
Reported

Reference: pages 344-347 (BPCE's sustainability report).

This is BPCE's own genuinely scoped data, not a cross-reference. Under heading 2.2.7.1 "(E1-6) Gross Scopes 1, 2 and 3 and Total GHG emissions", BPCE reports: gross Scope 1 emissions of 5,430 tCO2e in 2025 (up 2% from 5,339 in the 2023 reference year); gross Scope 2 market-based emissions of 727 tCO2e (down 69% year on year, from 2,354); and gross Scope 3 emissions of 202,425 tCO2e (down 1%), with "Goods and services purchased" the largest category at 151,718 tCO2e (p.344).

"Own footprint GHG emissions (market-based)" total 208,582 tCO2e. Financed-emissions portfolio figures are also disclosed: Scope 3 category 15 investments (banking) of 73,098,135 tCO2e and (insurance) of 17,887,994 tCO2e (p.345). "The scope of calculation of BPCE's own footprint covers 43 entities whose permanent contracts (CDI) represent 72% of the Group's employees" (p.346). The report notes: "The targets are set at the level of the Groupe BPCE's scope" (p.345).

E1-9(was E1-7)GHG removals and GHG mitigation projects financed through carbon credits
Not Material
E1-10(was E1-8)Internal carbon pricing
Not Material
E1-11(was E1-9)Anticipated financial effects from material physical and transition risks and potential climate-related opportunities
Omitted

S1 – Own Workforce

S1-1Policies related to own workforce
Reported

Reference: page 348 (BPCE's sustainability report, cross-reference); page 143 (Groupe BPCE's sustainability report).

BPCE's heading 3.1.3.1 "(S1-1) Policies related to the group's own workforce" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.348).

Groupe BPCE's policy table lists, among others, the "Group Workforce and Career Management (GEPP) agreement aligned with the VISION 2030 strategic plan over a period of three years, divided into three pillars: talent management (1), business development (2) and improvement of the employee experience (3)"; an Attractiveness policy; a Social dialogue policy; a Health and safety policy; and a Quality of life at work (QLW) policy, the latter built on "agreements signed since 2009 at branch level" (p.143).

S1-2Processes for engaging with own workforce and workers' representatives about impacts
Reported

Reference: page 348 (BPCE's sustainability report, cross-reference); pages 144+ (Groupe BPCE's sustainability report).

BPCE's heading 3.1.3.2 "(S1-2) Processes for engaging with the group's own workforce and workers' representatives about impacts" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.348).

Engagement is structured around the Social dialogue policy (regular discussions with trade unions through joint bodies at Banque Populaire and Caisse d'Epargne branches, Natixis and BPCE, p.143) and the GEPP Monitoring Committee, which involves employee representative organizations in tracking the three-year workforce and career agreement (p.143).

S1-2(was S1-3)Processes to remediate negative impacts and channels for own workforce to raise concerns
Reported

Reference: page 348 (BPCE's sustainability report, cross-reference); Groupe BPCE's sustainability report.

BPCE's heading 3.1.3.3 "(S1-3) Processes to remediate negative impacts and channels for the group's own workforce to raise concerns" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.348).

Groupe BPCE operates a group whistleblowing framework ("Groupe BPCE companies have a platform to collect reports relating to serious breaches of the Code of Conduct, laws, safety, environmental impact, or any inappropriate behavior in the workplace", p.188) open to all employees and third parties via a dedicated tool, supplemented by mandatory regulatory e-learning on whistleblower rights, duties and protections.

S1-3(was S1-4)Taking action on material impacts on own workforce
Reported

Reference: page 348 (BPCE's sustainability report, cross-reference); Groupe BPCE's sustainability report.

BPCE's heading 3.1.3.4 "(S1-4) Taking action on material impacts on the group's own workforce..." reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.348).

Actions flow from the policies summarised under S1-1: the GEPP workforce and career agreement, the Attractiveness policy addressing recruitment and retention, and the Health and safety policy "to prevent risks related to employee health and safety, by incorporating prevention protocols" (p.143), whose effectiveness is tracked through the S1-14 health-and-safety metrics reported directly in BPCE's own section (see S1-14).

S1-4(was S1-5)Targets related to own workforce
Reported

Reference: page 348 (BPCE's sustainability report, cross-reference); page 164+ (Groupe BPCE's sustainability report).

BPCE's heading 3.1.4.1 "(S1-5) Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.348).

Targets tied to the own-workforce IROs are carried through the GEPP agreement's three pillars (talent management, business development, employee experience, p.143) and tracked via the metrics BPCE itself discloses directly at its own scope: for example, the collective-bargaining coverage rate (100%, see S1-8) and the disability-employment rate (3.7%, see S1-12).

S1-5(was S1-6)Characteristics of the undertaking's employees
Reported

Reference: pages 349-351 (BPCE's sustainability report).

BPCE's own data, not a cross-reference. Under heading 3.1.5.2 "(S1-6) Characteristics of the undertaking's employees": total salaried employees were 35,873 at December 31, 2025 (up from 34,087 in 2024), split 18,934 male and 16,668 female, with 271 not declared (p.349).

"Countries in which BPCE has at least 50 employees representing at least 10% of its total number of employees": France, with 25,911 employees at December 31, 2025 (up from 25,206 in 2024) (p.350). The scope "excludes international subsidiaries of BPCE Lease, BPCE Equipment Solutions, and Pramex International"; Oney international subsidiaries are "covered only for some of the S1-6 indicators" (p.349).

S1-6(was S1-7)Characteristics of non-employee workers
Reported

Reference: page 352 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.3 "(S1-7) Characteristics of non-employees in the undertaking's own workforce": "The number of self-employed workers assimilated to the company's staff was 555 at December 31, 2025." Service providers are explicitly excluded from this population, and temporary workers "will be counted in terms of workforce (in number of people) and not in FTEs" (p.352).

S1-7(was S1-8)Collective bargaining coverage and social dialogue
Reported

Reference: pages 353-354 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.4 "(S1-8) Collective bargaining coverage and social dialogue": "Percentage of all employees covered by collective bargaining agreements: 100%" for 2025 ("In 2024, 100% of employees were covered by collective agreements", p.353).

"In the France scope, regulations require that all employees... be covered by a collective agreement and by a social dialog/employee representation" (p.353). A breakdown by coverage-rate band (0-19% through 80-100%) is presented separately for EEA and non-EEA employees for both 12/31/2025 and 12/31/2024 (p.354).

S1-8(was S1-9)Diversity metrics
Reported

Reference: pages 355-356 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.5 "(S1-9) Diversity metrics": breakdown by gender at senior management level was 39% women and 61% men in 2025 ("In 2024, the breakdown was 36% for women and 64% for men", p.356).

Age-group breakdown of own workforce at 12/31/2025: 17.2% under 30 (6,168 employees), 52.6% between 30 and 50 (18,871), and 29.4% aged 50 and over (10,542), against 17.1%/53.4%/29.5% respectively in 2024 (p.356).

S1-9(was S1-10)Adequate wages
Reported

Reference: page 357 (BPCE's sustainability report).

BPCE's own statement, under heading 3.1.5.6 "(S1-10) Adequate wages": "All Group employees receive an adequate wage in accordance with the applicable benchmarks. The adequate wage refers to the minimum social wages set by legislation or collective bargaining or applicable benchmarks" (p.357). No further BPCE-specific quantification is given beyond this affirmative statement.

S1-10(was S1-11)Social protection
Reported

Reference: page 357 (BPCE's sustainability report, cross-reference); pages 173-174 (Groupe BPCE's sustainability report).

BPCE's heading 3.1.5.7 "(S1-11) Social protection" reads in full: "No narrative: see section 3.1.5.7 (S-11) Social protection of the Group report" (p.357).

Groupe BPCE's text: "In France, all employees have social protection covering the five major life events: illness, unemployment, workplace accidents and disabilities, parental leave and retirement." Internationally, "according to the legal frameworks and local practices of the countries in which the group operates, all employees benefit from health and/or personal protection insurance." Caisse d'Epargne and Banque Populaire branch employees are covered by personal-risk and health plans "negotiated with the social partners at the level of" their respective branch (pp.173-174).

S1-11(was S1-12)Persons with disabilities
Reported

Reference: page 357 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.8 "(S1-12) Persons with disabilities": "Percentage of employees with disabilities in 2025 within the meaning of the CSRD: 3.7%. In 2024, this rate was 4.6%" (p.357). The metric is calculated as own-workforce registered with disabilities at December 31 divided by total own workforce at the same date.

S1-12(was S1-13)Training and skills development metrics
Reported

Reference: pages 357-358 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.9 "(S1-13) Training and skills development metrics": 87.3% of total salaried employees (29,377) participated in regular performance and career development reviews in 2025, versus 93.6% (27,112) in 2024; by gender, 88.7% of male and 87.2% of female employees were reviewed (p.357).

Average training hours completed in 2025 were 20 for both men and women overall (19 and 20 respectively in 2024), with permanent employees averaging 20 hours and temporary employees 15 hours (p.358).

S1-13(was S1-14)Health and safety metrics
Reported

Reference: pages 358-360 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.10 "(S1-14) Health and safety metrics": "Percentage of employees covered by the health and safety management system: 100%" in 2025 ("In 2024, the coverage rate... was 99.8%", p.358).

Occupational health and safety for 2025 versus 2024: zero fatalities (versus 2), 286 work-related accidents (versus 246), a work-related accident rate of 6.0% (versus 5.1%), and 8,508 days lost (versus 6,747) (p.359).

S1-14(was S1-15)Work-life balance metrics
Reported

Reference: page 361 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.11 "(S1-15) Work-life balance metrics": "Percentage of employees entitled to family leave: 100%. Percentage of employees who took family leave: 10.5%" in 2025 ("In 2024, the overall rate of employees entitled to family leave was 100%. The overall rate of employees who took family leave was 5.1%", p.361). By gender, 13% of eligible women and 9% of eligible men took family leave (p.361).

S1-15(was S1-16)Compensation metrics (pay gap and total compensation)
Reported

Reference: pages 362-363 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.12 "(S1-16) Pay metrics (pay gap and total remuneration)": "the gender pay gap for the BPCE scope excluding Natixis is 17.6%. For the Natixis scope, the gap is 34.6%. In 2024, the gap for BPCE excluding Natixis was 18.9%, for the Natixis scope it was 34.1%" (p.362).

"The ratio of the total annual remuneration between the highest-paid employee and the median of other employees was 101.1 in 2025. In 2024, this ratio was 90.6" (p.363).

S1-16(was S1-17)Incidents, complaints and severe human rights impacts
Reported

Reference: page 364 (BPCE's sustainability report).

BPCE's own data. Under heading 3.1.5.13 "(S1-17) Incidents, complaints and severe human rights impacts": "BPCE lists 27 reports of harassment/discrimination that led to investigations, 5 of which have resulted in a disciplinary sanction. No fines, penalties or compensation for damages related to harassment or discrimination were recorded in 2025 (final court decisions)" (p.364).

"BPCE is not affected by the indicators below, as no complaints were recorded in the reference year", including OECD National Contact Point complaints and serious human-rights/employee-related incidents under the UN Guiding Principles or OECD Guidelines (p.364).

S3 – Affected Communities

S3-1Policies related to affected communities
Reported

Reference: page 367 (BPCE's sustainability report, cross-reference); pages 185-186 (Groupe BPCE's sustainability report).

BPCE's heading 3.2.3.1 "(S3-1) Policies related to affected communities" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.367).

Groupe BPCE's text: "As part of its VISION 2030 strategic project, Groupe BPCE has announced its ambitions for 2026, aimed at strengthening its positive impact in relation to specific sectors or communities. To date, there are no formal policies within the meaning of the ESRS" (p.186). Named strategic ambitions include being "the benchmark player in regional competitiveness by supporting SMEs and mid-sized companies" and "the leading banking group for promoting access to housing for all" (p.186). "No material negative impacts on human rights were identified in relation to affected communities" (p.186).

S3-2Processes for engaging with affected communities about impacts
Reported

Reference: page 367 (BPCE's sustainability report, cross-reference); page 187 (Groupe BPCE's sustainability report).

BPCE's heading 3.2.3.2 "(S3-2) Processes for engaging with affected communities about impacts" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.367).

Groupe BPCE's network engages local ecosystems directly: with companies via "the Chambers of Commerce and Industry (CCI), the Chambers of Trades and Crafts, and the regional delegations of employer organizations"; with social and solidarity economy players via "the Regional Chambers of the Social and Solidarity Economy (RCSSE)"; and with public authorities, for which "Caisses d'Epargne are in constant contact with various public bodies... and forge partnerships at both national and local levels" (p.187).

S3-2(was S3-3)Processes to remediate negative impacts and channels for affected communities to raise concerns
Reported

Reference: page 367 (BPCE's sustainability report, cross-reference); page 188 (Groupe BPCE's sustainability report).

BPCE's heading 3.2.3.3 "(S3-3) Processes to remediate negative impacts for affected communities to raise concerns" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.367).

"Groupe BPCE companies have a platform to collect reports relating to serious breaches of the Code of Conduct, laws, safety, environmental impact, or any inappropriate behavior in the workplace. This whistleblowing framework is open to all employees and third parties." For 2025: "No alert was raised via Whispli, Groupe BPCE's whistleblowing channel" (p.188). Additional channels include regular customer satisfaction monitoring and "BPCE L'Observatoire" studies of social and economic trends (p.188).

S3-3(was S3-4)Taking action on material impacts on affected communities
Reported

Reference: page 367 (BPCE's sustainability report, cross-reference); pages 188-193 (Groupe BPCE's sustainability report).

BPCE's heading 3.2.3.4 "(S3-4) Taking action on material impacts on affected communities..." reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.367).

"Groupe BPCE's VISION 2030 strategic project and 2026 ambitions... are broken down into action plans, piloted within the framework of programs", each under the direct responsibility of a member of the Executive Management Committee or Executive Committee and reviewed quarterly (p.188). Action plans by network are detailed for each community group, e.g. the Banque Populaire network's role as "the leading bank for corporate clients for the sixteenth year (KANTAR 2025 PME PMI survey)" (p.189).

S3-4(was S3-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Reference: page 367 (BPCE's sustainability report, cross-reference); pages 193-194 (Groupe BPCE's sustainability report).

BPCE's heading 3.2.4 "(S3-5) Metrics and targets" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.367).

Targets include "+15% of active professional customers for BP and +21% of active companies for CE by 2026" and, for the social and solidarity economy, social housing and public sector, "the ambition by 2026 is to increase the financing... by 8%", with "production increased by 8.5% compared to the 2023 base year" as of December 31, 2025 (p.194). "The number of green or social issues made by the group in 2025... amounted to eight for a total of EUR4,167 million (compared to five for a total of EUR3,650 million in 2024)" (p.193).

S4 – Consumers and End-users

S4-1Policies related to consumers and end-users
Reported

Reference: page 368 (BPCE's sustainability report, cross-reference); pages 196-197 (Groupe BPCE's sustainability report).

BPCE's heading 3.3.3.1 "(S4-1) Policies related to consumers and end-users" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.368).

Groupe BPCE's policy table lists a "Personal data protection policy", describing "the organization and governance of Groupe BPCE to ensure the protection of personal data", and a "2025-2027 multi-year accessibility plan" under the Code of Conduct and Ethical Standards, which commits the group to "Protect the interests of customers and cooperative shareholders" and "Communicate seamlessly" (pp.195-196).

S4-2Processes for engaging with consumers and end-users about impacts
Reported

Reference: page 368 (BPCE's sustainability report, cross-reference); page 195 (Groupe BPCE's sustainability report).

BPCE's heading 3.3.3.2 "(S4-2) Processes for engaging with consumers and end-users about impacts" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.368).

"Groupe BPCE is in continuous dialogue with its stakeholders. The stakeholder consultation process within Groupe BPCE is based on mechanisms that involve its stakeholders in identifying and evaluating impacts, risks, opportunities and levers for improvement" (p.195), summarised in the same stakeholder-dialogue table used for SBM-2 (p.69).

S4-2(was S4-3)Processes to remediate negative impacts and channels for consumers and end-users to raise concerns
Reported

Reference: page 368 (BPCE's sustainability report, cross-reference); pages 195-196 (Groupe BPCE's sustainability report).

BPCE's heading 3.3.3.3 "(S4-3) Processes to remediate negative impacts and channels for consumers and end-users to raise concerns" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.368).

Remediation sits within the Code of Conduct and Ethical Standards' client-protection principles and the group's data protection governance (Data Protection Officer, audit and internal control, data breach management) described under the Privacy Protection policy row of the S4-1 policy table (p.196).

S4-3(was S4-4)Taking action on material impacts on consumers and end-users, and approaches to managing material risks and pursuing material opportunities related to consumers and end-users, and effectiveness of those actions
Reported

Reference: page 368 (BPCE's sustainability report, cross-reference); pages 195-196 (Groupe BPCE's sustainability report).

BPCE's heading 3.3.3.4 "(S4-4) Taking action on material impacts on consumers and end-users..." reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.368).

"Four issues were identified as material: protection of privacy, access to products and services, responsible marketing practices, and non-discrimination" (p.195). Actions include the "Fragile clientele offer", "Support to microcredit", "Securing the banking offer of protected persons", and "Awareness-raising, training, change management, diagnostics and audits for digital accessibility" (p.196).

S4-4(was S4-5)Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities
Reported

Reference: page 368 (BPCE's sustainability report, cross-reference); pages 210-211 (Groupe BPCE's sustainability report).

BPCE's heading 3.3.4.1 "(S4-5) Targets related to managing material negative impacts..." reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.368).

"As part of the VISION 2030 strategic project, Groupe BPCE aims to support 11,000 local social entrepreneurship projects per year." Progress: "At December 31, 2025, 10,356 local projects had been financed by the Banques Populaires and the Caisses d'Epargne (compared to 10,589 in 2024)" (p.211). A "2025-2027 multi-year accessibility plan" also targets digital accessibility compliance with the RGAA standard (p.211).

G1 – Business Conduct

G1-1Business conduct policies and corporate culture
Reported

Reference: page 369 (BPCE's sustainability report, cross-reference); pages 212-214 (Groupe BPCE's sustainability report).

BPCE's heading 4.1.2.2 "(G1-1) Corporate culture and business conduct policies and related action plans" reads: "See the corresponding section in Groupe BPCE's sustainability report" (p.369).

Groupe BPCE's "Code of Conduct and Ethical Standards highlights the rules of conduct and best practices to be adopted while respecting the best behavioral standards of transparency and confidentiality... The principles of ethical and professional conduct set out in this code are considered fundamental by the Supervisory Board, Management Board and Executive Management Committee, as well as by all group executives" (p.213), distributed via mandatory regulatory e-learning.

G1-2Management of relationships with suppliers
Reported

Reference: pages 369-370 (BPCE's sustainability report, cross-reference); pages 219-221 (Groupe BPCE's sustainability report).

BPCE's heading 4.2 "(G1-2) Management of relationships with suppliers" and its sub-sections (payment policy, supplier relations, selection criteria) all read: "See the corresponding section in Groupe BPCE's sustainability report" (p.369).

Groupe BPCE's supplier payment target is "to pay suppliers within an optimal 28 days after the issuance of the invoices"; the group average reached was "22 days" in 2025, monitored by BPCE Achats & Services under a framework set up in 2020 (p.220). Supplier relations also include a "Responsible Supplier Relations and Purchasing certification (RFAR)" and a "Supplier voices" survey (p.220).

G1-2(was G1-3)Prevention and detection of corruption and bribery
Omitted
G1-3(part of MDR-T/GDR-T disclosures)Targets related to business conduct
Reported

Reference: page 213 (Groupe BPCE's sustainability report, footnote to the G1 policy/action table).

Back-filled from the business conduct chapter, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered disclosure requirement, since G1-3 Targets became a standalone DR only in the 2025/2026 ESRS. BPCE's own section incorporates Groupe BPCE's text by cross-reference for the adjoining G1-1/G1-3 headings (p.369).

Groupe BPCE's own footnote states plainly: "In the context of the 'Business conduct' sub-topic (G1-1), the definition of quantified targets has not been adopted at this stage, as management is mainly based on a framework comprising policies, a framework for managing the associated non-compliance risks (prevention, detection, remediation) and monitoring via metrics and actions" (p.213). Consistent with MDR-T's other limb, effectiveness is tracked via the corruption-risk mapping, mandatory training coverage and supplier due-diligence measures described under G1-3 rather than a numeric target.

G1-4Incidents of corruption or bribery
Omitted
G1-5Political influence and lobbying activities
Not Material
G1-6Payment practices
Reported

Reference: page 370 (BPCE's sustainability report).

BPCE's own data, not a cross-reference. Under heading 4.2.4.1 "(G1-6) Payment practices": "BPCE undertakes to comply with regulatory payment terms... a period of 60 days from the date of receipt of the goods or performance of the services. In 2025, 95% of payments (by amount) met this commitment, (compared to 94.3% in 2024)" (p.370).

"BPCE complies with the policy implemented by the Group to pay suppliers within 30 days... and the average payment period... amounts to 24 days, (compared to 27.38 days in 2024). Finally, there are no ongoing legal proceedings concerning late payments" (p.370). One limitation is explicitly flagged elsewhere: the MDR-M datapoint on standard payment terms "by major supplier category" is "not published... given the unavailability of data" for 2025 (p.370).