LEGAL NOTICE

If you send your report from Russia, please use this link:
Если вы делаете заявление из России, пожалуйста, используйтеу ссылку:
https://report.whistleb.com/societegeneralerussia

FOREWORD

The WhistleB tool, further described below, is a global channel through which a whistleblower is given the opportunity to report a particular situation he/she becomes aware of, which does not comply with the rules governing the conduct of the Group’s activities or the ethical standards expected, or which may be in breach of applicable laws and regulations.

Please note that the legal notices below are based on the French whistleblowing regime – in particular provided by the ‘Sapin 2’ law. A different whistleblowing regime may apply for other countries.

In several of the countries in which Societe Generale operates, there may be various channels through which whistleblowing alerts can be raised. If you a member of staff at SG, please refer to your local whistleblowing policy to get further information about the various channels which can be used, in addition to the WhistleB tool. Please also note that where a case is raised using the Group WhistleB tool, this may be referred to your local compliance officer.

COULD YOU BE A WHISTLEBLOWER ?

The whistleblower may be any employee, external or part-time collaborator and, within the scope of a duty of care, any service provider with whom an established commercial relationship is maintained (subcontractors or suppliers).

In order to benefit from the protective status of whistleblower, the person making the report must:

• Be a natural person and
• Act impartially and
• Act in good faith.

Some national regulations may provide for different and/or additional conditions (e.g. in France, having personal knowledge of the facts).

YOU HAVE A RIGHT TO REPORT

The right to report is a basic right afforded to everyone to express themselves when they believe that they have good reason to consider that an instruction they have received, an operation under investigation or, more generally, a particular situation does not appear to comply with the rules governing our Group's business conduct.

The mechanism set up by Société Générale for collating reports complies with the provisions of the law on transparency, the fight against corruption and the modernisation of economic activity (law No. 2016-1691 of 9 December 2016, known as the "Sapin 2" law), and the law pertaining to the duty of vigilance incumbent upon parent companies and ordering companies (law No. 2017-399 of 27 March 2017), which specifies the legal regime applicable to reports and the protection of whistleblowers.

As such, you are able to report any situation of sufficient gravity, including the detection of a crime or offence, a serious and manifest violation of an international treaty, a serious violation of a law or regulation, or any serious threat to the public interest.

This system for collating reports makes it possible, on the one hand, to protect the person who – acting in good faith and in a non-abusive manner – made the report, and, on the other hand, to detect a serious situation in order to limit the Group's exposure to the related risks.

YOU CAN EXERCISE YOUR RIGHT TO REPORT UNDER THE CONDITIONS PROVIDED FOR THIS PURPOSE

In order for a report to be eligible under this mechanism, specific legal conditions must be met that are both applicable to the whistleblower and the reported facts.

The whistleblower must in principle identify himself/herself, although it is also possible to make an anonymous report. In both cases:

• Checks will be initiated to determine the veracity and seriousness of the reported facts. For this purpose, the factual elements must be sufficiently precise and corroborated, and may therefore require knowledge of the whistleblower's identity;
• Specific precautions will be taken in dealing with this report, such as a preliminary examination and the possible use of experts to establish the legal status and investigate the facts.

These conditions, which partly determine the status and protection of the whistleblower, may differ depending on the country and the applicable law. It is therefore recommended that employees, external and part-time collaborators read the normative documentation provided for this purpose. It is available on the Group's intranet site. It may be supplemented, where necessary, by entities' own normative documentation to take into account local regulatory specificities.

The strict confidentiality of information is guaranteed throughout the process, in accordance with applicable regulations. The right to ‘blow the whistle’ will have to be carried out in compliance with Group and local provisions, for example those relating to professional secrecy, the protection of personal data or location of data. Thus, in some countries, it will be appropriate to anonymise the names of clients and persons concerned or to use the only local whistleblowing device.

WHAT FACTS CAN BE REPORTED ?

The reports covered by the whistleblower scheme cover, in particular:

• Crimes or misdemeanours (including corruption),
• Serious and manifest violation of an international treaty,
• Serious violation of a law or regulation,
• Any serious threat to the public interest,
• Serious violation of human rights and fundamental freedoms, the health and safety of persons and the environment,
• Conduct or situation contrary to the Group's code of conduct

Some national regulations may not provide for the status of whistleblower for all serious situations that are reported.

Reports may not relate to information covered by national defence secrecy, medical confidentiality or lawyer-client privilege.

Reports may not relate to information covered by:

• national defence secrecy,
• medical confidentiality,
• lawyer-client privilege,
• state security,
• state secrets.

or whose disclosure would be contrary to any applicable laws or regulations. Reports shall directly concern the entity(ies) within the Société Générale group.

WHO RECEIVES THE REPORTS ?

The use of this mechanism is not the only possible reporting channel.

The right to report of Société Générale collaborators can be exercised at several levels:

Firstly, by using a direct or indirect reporting line or by reporting directly to the local Chief Compliance Officer (CCO),

Secondly, if these methods of communication are not appropriate, by reporting to the Group Compliance Director directly via the reporting tool, which is based on a secure platform guaranteeing the protection of personal data and strict confidentiality.

For service providers with whom the Group has an established commercial relationship (subcontractors and suppliers), the right to report is exercised directly via the reporting tool described above.

YOU BENEFIT FROM SPECIFIC LEGAL PROTECTION

All reports will be treated securely, and the confidentiality of your identity will be ensured, both at an information system level and at organisational level.

The reporting channel is provided by an external partner, the Whistleblowing Centre, to keep your identity confidential. The reporting process is encrypted and password-protected.

If you are eligible for the status of whistleblower provided for by applicable law, you will be protected from any retaliation, discriminatory measures, sanctions or dismissal with regard to you personally.

WHAT RISKS COULD YOU BE EXPOSED TO ?

If the above-mentioned legal conditions are not met, you will not, in accordance with the law, be able to benefit from the status of whistleblower or the appropriate protection regime.

In addition, any report must be made in a responsible, non-defamatory and non-abusive manner. Should this not be the case, the author of the report is exposed to (i) penalties, potentially of a criminal nature, for false allegations or defamation, and (ii) potential disciplinary proceedings.

REMINDER OF OTHER EXISTING SYSTEMS :

Clients: special customer support center
On the other hand, with regard to claims, customers must use the customer support center, which is governed by regulations and is intended specifically for them. In the event of persistent disagreement over the handling and outcome of the claims, this claim process may be escalated to the Société Générale Group Mediator, or even the Mediator of the French Financial Markets Authority (AMF) or another national authority if necessary.
https://sg29haussmann.societegenerale.fr/fr/contact/reclamations/

Suppliers: as a reminder, in case of litigation (out of the whistleblowing case), you may directly address your claims to Internal Ombudsmen / Mediator available at the following address (as indicated on the internet website of the Group [https://www.societegenerale.com/fr/travailler-ensemble/fournisseurs/focus-pratiques-achats-responsables]):

Société Générale
Médiateur interne des relations Inter-Entreprises
SEGL/DIR
Tours Société Générale
75886 Paris Cedex 18