BNP Paribas SA

BNP Paribas has long engaged with the public authorities. It has done so with the utmost respect for ethical principles and transparency. In the aftermath of the numerous reforms put through since the 2007-2008 financial crisis, and in order to remain an active participant in the public forum, the Group has decided to strengthen the governance of its public affairs. Accordingly, in 2012, the Group's Executive Committee adopted a "Charter for responsible representation with respect to the public authorities", which applies to all the Group's employees and includes a series of fundamental commitments to integrity, transparency, social responsibility and respect for great universal democratic values. [...] Established in late 2012 to strengthen governance of the Group's public affairs, the Institutional Affairs Department (DAI) in particular is in charge of ensuring the consistency and integrity of the Group's stances with public authorities and to ensure compliance with the Charter for Responsible Representation. On behalf of the Group's Management Board, the DAI assembles and coordinates the following committees: (i) Prudential Affairs, (ii) Recovery and Resolution, (iii) Group-ECB Relations and Group Supervision; (iv) European Public Affairs; and (v) French Public Affairs. The heads of public affairs of BNP Paribas's business lines meet each month the framework of the Public Affairs Coordination Committee, chaired by the Group Head of Institutional Affairs. These business lines and functions are charged with conducting first-level controls of their interest representation activities in France and of compliance with regulations and internal procedures applicable in this area. Second- and third-level controls are conducted, respectively, by the Group' Compliance and Inspection Générale departments. [...] The Group's employees shall not carry out public representation activities without the authorisation of their superiors. They shall undertake to report on their activities to their superiors and to the Public Affairs Department in respect of the most important matters.

Scaling up our commitment to a net-zero economy also requires that the Group strengthens its processes and steering tools to support evolving needs and standards, and strengthens its governance. To that effect, BNP Paribas created Climate Analytics & Alignment, a team designed to support our front officers as they engage with clients on their transition to a low-carbon economy and steer the Group's portfolio alignment towards net-zero by 2050. More specifically, the team closely collaborates with the Low Carbon Transition Group and concentrates its efforts on: - Developing the methodologies and industrialising the process for the review of carbon intensive sectors - Monitoring the impact of our commercial strategy on the metrics and targets defined for each carbon intensive sector. **Methodology-wise, this team is positioned as a centre** **of excellence for the Group, leveraging on a mutualised** set-up within the Group. It will also make sure that the work done on our portfolio alignment measurement constantly remains consistent with best market standards and supports the evolving needs of our clients, front officers and regulators. This strengthening of our steering tools will allow us to accelerate industrialisation of our portfolio review and facilitate our capacity to accompany our clients while delivering our 2025 commitments on the net-zero economy pathway. [...] Strengthened Governance in Sustainable Finance In 2021, the Group's ESG governance system was extended to all aspects of the Company and its structure was accentuated. A Sustainable Finance Strategic Committee, chaired by the Director and Chief Executive Officer, was set up in November 2021. This bimonthly committee, in which members of Executive Management, the Company Engagement Department and the heads of the business lines and functions involved take part, approves the overall strategy in terms of sustainable finance, decides on the overall commitments made by the Group and the main focuses of Sustainable Finance commercial policies, then monitors their operational implementation. At the same time, a Sustainable Finance Infrastructure Committee was also created in 2021 to industrialise ESG processes, data and reporting. Its mission is to meet the growing needs of clients, regulators and investors. Around the Deputy Chief Executive Officer, it brings together key contributors from different business lines and functions. Finally, an ESG Regulatory Committee at Executive Management level was set up to assess the operational consequences of the main new regulations.

With regard to regulatory organisations, governments and parliamentarians, in November 2012, BNP Paribas adopted a "Charter for responsible representation with respect to the public authorities". In 2017, BNP Paribas was registered in the digital register of lobbyists, managed by the Haute Autorité pour la Transparence de la Vie Publique (HATVP, High Authority for Transparency in Public Life). In February 2014, the Group signed the joint declaration on transparency in lobbying, introduced by Transparency International France, then in May 2019 its revised version, thus renewing the commitments made in 2014 as a follow-up to the provisions of the Sapin 2 law on representation of interests. The dedicated website of its Public Affairs France Department details its work in the area of responsible representation. The Group's public positions concerning banking and financial regulations are also available on its website.

##### 2.4 Implementation for financing and services activities

Information on the criteria of this policy is obtained from customers in the oil and gas sector by BNP Paribas customer relationship managers and external data providers.
Before entering into a business relationship, BNP Paribas examines the performance of the energy companies with regard to this policy. For an existing customer that does not comply with these requirements, a dialogue will then be initiated in order to find an acceptable solution and improve the situation as quickly as possible. If this dialogue does not result in regular progress, BNP Paribas will decide not to undertake any new business with this customer and reserves the right to reassess existing relations taking into account the contractual agreements in force.

##### 2.5 Implementation for investment and asset management activities

Companies that do not meet the criteria set out in 2.2.1. will be placed on BNP Paribas Asset Management's exclusion list. By exception, companies that do not meet the criteria set out in 2.2.1 may be added to a monitoring list, meaning they are eligible for investment subject to regular review, if they have credible climate commitments and realistic transition plans as set out in section 2.2.2.1.

For further details on these exclusion and monitoring lists, please refer to BNP Paribas Asset Management's Responsible Business Conduct (RBC) policy[18].

BNP Paribas will implement these requirements in the context of its investment and asset management activities through the following measures:

- BNPP Asset Management draws up monitoring and exclusion lists and applies exclusions in connection with its investments by discontinuing any new investment and liquidating any investment under way in the relevant issuers within a reasonable period of time and depending on market conditions in accordance with the procedures set out in the RBC;

- When applied to other activities within BNP Paribas, these lists become the "monitoring and exclusion lists of BNP Paribas' investment and asset management activities";

- BNP Paribas Cardif will implement this policy by applying the "monitoring and exclusion lists of BNP Paribas' investment and asset management activities" in the context of its investment activities. BNP Paribas Cardif will no longer invest in, and will liquidate any existing investment[19] in companies excluded by this policy within a reasonable period of time, depending on the solvency and accounting constraints of the insurer.

- In its capacity as distributor, BNP Paribas Wealth Management, BNP Paribas' private bank, provides its clients with BNP Paribas products that comply with this policy and encourages external managers to adopt the standards defined in this policy.

Describe the process(es) your organization has in place to ensure that your engagement activities are consistent with your overall climate change strategy[…]The Group follows the "Charter for responsible representation with respect to the public authorities

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