Credit Agricole SA

## 6. IMPLEMENTATION OF THE POLICY WITHIN THE GROUP

For the needs of their business lines, the Group's entities formalise procedures for the operational implementation of this policy, taking into account their specific characteristics.

An entity may not adopt business line procedures less demanding than this policy.

These implementation procedures particularly include:

- A governance and delegation/decision-making system,

- The essential application specifications, particularly those relating to the dialogue they intend to conduct with
companies in the sector.

- A system for monitoring that application.

More importantly, we have set up a governance framework with involving senior banking, sustainable banking coverage and the power sector to exit, onboard or accelerate our support to the clients depending on their own decarbonization strategies. [...] Of course, we start with our organisation, and we have decided to embed at each level of our organisation, the highest level of the governance, which is the Board and its different committees, but also the executive committee and many more committees and decision circles in the organisation in order to make sure that our policies are followed, developed, fine-tuned permanently in order to adapt to the reality. [...] Second element, because we are again, an organisation in which we must process, all our investments, all our decisions. We have embedded - we have started this year actually to embed into our budget processes, CO2 emissions as another scarce resource we have to manage. You know that we permanently try to manage liquidity and risk-weighted assets. And now we have started in the 2024 budget process to integrate carbon emissions as another scarce resource in order to make sure that we do not only follow the achievements of all these strategies, but we have really enhanced the levers in order to make sure that they happened really, in reality. [...] Third point, of course, we must make sure that we have in our organisations, all the people that really have the skills and the expertise to handle those matters. We have roughly 500 plus people that are really experts of these energy transition issues that are at CACIB, are in different entities of the Group in order to develop our policies. But much more important, we have decided that all our staff must be trained on these issues, and we have started to do so. So now 43% of our staff is already trained and has got a certain level of expertise on all these issues. And the target is, of course, that 100% of our staff is fully trained on environmental issues and energy transition issues. We are taking regular decisions on credit granting, and we have now completely embedded in our credit processes these energy transition issues and climate risks issues. [...] And last point when we decide, or when we update any kind of policy, we integrate in those policies, in those frameworks, the climate issues. So simply - and you have much more details in the appendix of this document, but I wanted simply to give you these highlights in order really to make you feel that all that has been presented today here is not only the nice story that is presented, but that it's really part of all our decision-making processes internally.

To promote responsible relationships with its customers, the Group has established several guidelines:  An Anti-corruption Code of Conduct, integrated into the Rules of Procedure, which specifies the appropriate behaviour to be adopted by employees when faced with situations of risk and reinforces ethical behaviour towards all stakeholders of the Group (URD 2021, chapter 2, p.62)  A responsible lobbying policy based on the Internal Code of Business Conduct and a Lobbying Charter adopted in 2013 (URD 2021, chapter 2, p.95)  A cybersecurity strategy and data privacy policy applying a range of IT security rules to protect its customers' data and ensure the availability of the IT systems it requires to provide services to its customers. Crédit Agricole also develops its employees' awareness of cyber threats though training, targeted actions and themed exercises (URD 2021, Chapter 2, p.95).  A fraud prevention system with dedicated teams and appropriate tools, detection and control procedures. In 2021, 95%(3) of employees of Crédit Agricole S.A. and its subsidiaries had been trained in fraud prevention (URD 2021, Chapter 2, p.62).

**4. Implementation of the policy within the Group**

The Group's entities formalise, for the needs of their business lines, the procedures for the operational implementation of this policy, with appropriate consideration of the specific characteristics of their activities and businesses.

These procedures include in particular:

- A governance and delegation/decision-making system,
- The specification of the essential operational procedures for the application of policy,
- A system for monitoring implementation.

Overall thermal coal exposures are monitored at Group level.

Compliance with the environmental and social management plans and conditions will be monitored as part of the annual review process of the operations. [...] As such, the assessment of its clients' compliance with this Policy will be conducted on the occasion of the annual review of the relationship. Commitments to the principles of the IPIECA, the EITI and the relevant initiatives listed under section 3 will be taken into consideration when assessing activities not located in high income OECD countries. The bank will also assess whether the client monitors and assesses impacts and mitigation measures, and is publicly reporting on these aspects (website, annual report[6],…). [...] In case of a significant difference between the client's policy and the reference frame of the Policy, and when, in particular, a significant portion of the client's activity or investments relates to exclusion criteria, the Bank will seek to understand the client's strategy and the recommendation of the CERES committee will be required. [...] The decision to enter into relation with a new client falling under the scope of the Policy will only be taken after an analysis of the activities of the client according to the same criteria. This analysis shall confirm, if needed at a CERES committee level, that the client practices comply with the principles of the Bank Policy. [...] Transactions that present uncertainty with respect to compliance with the Policy shall be referred to the CERES committee for recommendation. If the committee considers that the transaction does not conform to the Policy, such transaction will be subject to a final arbitration by the General management of Crédit Agricole CIB.

Crédit Agricole S.A. adopted a Lobbying Charter in 2013 which is in the process of being revised for publication in 2023. The charter applies to Crédit Agricole S.A. and all of its entities. [...] The Group Public Affairs department is responsible for lobbying on behalf of the Crédit Agricole Group. Also subject to the Internal Code of Business Conduct and the monitoring of its budget by the Finance department, the Group Public Affairs department regularly communicates key messages and positions advocated to internal bodies, including the Executive Committee, the Management Committee and the Specialised Committees of the Board of Directors. [...] The Societal Project department has a specialist in charge of regulatory issues who contributes to ensuring that all the bank's direct and indirect activities that influence policy are consistent with its overall climate change strategy. As such, the Societal Project department can be consulted directly by the business lines, or by the Public affairs department, which supervises all the bank's activities in terms of position taking and position statements.

Governance has been strengthened to place climate commitments at the heart of the Group's strategy with the creation of two new committees: [...] The Societal Commitment Committee, comprising members of the Board of Directors, [...] The ESG Strategy Committee, chaired by the Chief Executive Officer of Crédit Agricole SA. [...] All the trajectories and commitments will be monitored by these committees, and on quarterly basis at the highest level of the entities concerned.

Governance has been strengthened to place climate commitments at the heart of the Group's strategy with the creation of two new committees: o The Societal Commitment Committee, comprising members of the Board of Directors, o The ESG Strategy Committee, chaired by the Chief Executive Officer of Crédit Agricole SA. All the trajectories and commitments will be monitored by these committees, and on quarterly basis at the highest level of the entities concerned.

Transactions that present uncertainty with respect to compliance with the Policy shall be referred to the CERES committee for recommendation. If the committee considers that the transaction does not conform to the Policy, such transaction will be subject to a final arbitration by the General management of Crédit Agricole CIB. [...] The regular reviews of the relationship with the client will address an update of the compliance of the client with the principles of the present Policy.

Our commitments will be driven by a dedicated governance, structured around five pillars that will support their strategic steering and allow us to continuously reconcile regional economic development with anti-climate change goals:

- A "Societal Engagement Committee" comprising executive managers of the entities and Regional Banks, in charge of co-building the alignment of the Group Climate Strategy with the Paris Agreement and ensuring that all Group entities are on board.

- A Scientific Committee made up of the Group experts, with the support of academic partners, in charge of conducting high-level scientific analysis and informing the decisions of the Societal Engagement Committee.

- An information system designed to monitor the Group data used by the Scientific Committee and to direct strategic decisions consistently.

- Regularly and individually revised sectoral policies, based on the research and recommendations of the Scientific Committee.

- Climate reporting will be prepared in accordance with the TCFD (Task Force on ClimateRelated Disclosures) recommendations by 2020.

In order to meet stakeholders' expectations, and because we believe in the virtues of dialogue, the Group Climate Strategy will be certified by an independent third party body, thus ensuring its proper implementation, oversight and transparency.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]Engagement with policy-makers has essentially consisted in presenting our views on the respective regulations, sharing our practices as well as information on market functioning and last but not least in providing feedback regarding the interconnection of these sustainable finance regulations and the crucial need to ensure consistency across them, both in terms of application timeline and legal definitions and principles.

Does your organization have a public commitment or position statement to conduct your engagement activities in line with the goals of the Paris Agreement?[…]Yes