Code of conduct

1- OUR COMMITMENTS

4

2- USING OUR CODE OF CONDUCT

5

3- OUR RULES OF CONDUCT

8Everyday ethical practice

9

Our rules of conduct regarding customer
and supplier relations

11

1.

Customer relations

122.

Customers’ personal data133.

Fair and equitable choice of supplier

14

4.

Responsible supplier relations15

5.

Competition

16

Our rules of conduct regarding social,environmental and societal issues

17

6.

Protection of employees’ data

18

7.

Health and safety at work198.

Non-discrimination

20

9.

Diversity and gender equality

10. Combating harassment
11.

Extra-professional activities

21
22
23

12. Environmental strategy

24

Our rules of conduct regarding anti-corruption

25

13. Fight against bribery

26

14. Fight against influence peddlingand interaction with public officials

27

15. Fight against facilitation payments28
16. Conflicts of interest

29

17.

30

Gifts and invitations18. Lobbying and financing political parties

31

19. Patronage and charitable actions32

20. Sponsorship

33

Our rules of conduct protecting Amundi
and its reputation

34

21. Confidentiality

35

22. Fight against the money laundering and financing of terrorism

36

23. Fight against tax evasion

37

24. International sanctions38

25. Prevention of fraud

39

26. Prevention of market abuse

40

27. Using social networks

41

Ensuring that each one of us acts in an ethical manner is at the heart of our
responsibility as an asset manager and one of the pillar s of the trust our customer splace in us.
This re sp on sibilit y is f ur the r e n h a n ce d by our p o sition a s th e Europe a n le a de r ina s s et ma nage me nt, a n d by our commitme nt to re spon sible inve stme nt, for which
we must set the example.
Putting the commitments in our Code of Conduct into practice will strengthen
the development of our busine s s in the intere st s of our client s , shareholder s andemployees.

YVES PERRIER,

CEO of Amundi

A MU N DI / CODE OF CON D U CT

3

1

Our
commitments
I N 2 0 1 7, C R É D I T AG R I C O L E D R E W U P A C O D E O F E T H I C S F O R A L L
O F I T S E N T I T I E S W H I C H U N D E R P I N S T H E P R OX I M I T Y, R E S P O N S I B I L I T Y
A N D S O L I DA R I T Y VA L U E S O F T H E G R O U P. T H E C O D E S U M M A R I S E S
T H E P R I N C I P L E S O F T H E AC T I O N S A N D T H E C O N D U C T T O B E R E S P E C T E D
V I S -À -V I S A L L G R O U P S TA K E H O L D E R S , E M P LOY E E S , S U P P L I E R S
A N D S E R V I C E P R OV I D E R S , A S W E L L A S G OV E R N M E N T
R E P R E S E N TAT I V E S , N O N - P R O F I T A S S O C I AT I O N S , N G O S ,S H A R E H O L D E R S A N D I N V E STO R S .

The Amundi Code of conduct puts into practice the commitments of the Code of
Ethics and is designed to guide our everyday actions, decisions and conduct. It is
the fruit of a collaborative approach between the Company’s different businesslines (Retail and Institutional Marketing, Purchasing, Compliance, Legal, Human
Resources, Corporate Social Responsibility, Communications, etc.).
Beyond compliance with legislative, regulatory and professional rules, the Code of
conduct, which applies to all of our operations, reflects our commitment to carryingout our activities with the highest ethical standards and professionalism and toacting in the best interests of our customers.

4

A M U N D I / CO D E O F CO ND U CT

2

Using
our Codeof conduct

A MU N DI / CODE OF CON D U CT

5

A M U N D I ’ S CO D E O F CO N D U C T I S A TO O L A N D
A G U I D E D E S I G N E D TO C L A R I F Y O U R P R O F E SS I O N A L
O B L I G AT I O N S A N D E N A B L E U S T O B E H AV E I N A WAY
T H AT I S I N L I N E W I T H T H E E T H I C S A N D VA L U E S
O F A M U N D I A N D T H E C R É D I T AG R I C O L E G R O U P.

TO WHOM DOES THE CODE APPLY?
The Code of conduct applies to everybody in the
Company, be they directors, managers, employees,
regardless of their position and role within Amundi, bothin France or abroad.

The various topics are classified into four sections:“customer and supplier relations”; “social, environmental
and societal issues”; “anti-corruption”; and, “protecting
Amundi and its reputation”. Note that conflicts of interest,
which is a cross-functional topic, is addressed in the anticorruption section.
Practical cases illustrate the principles presented in the
Code.

WHAT ARE ITS OBJECTIVES AND HOWSHOULD THE CODE BE INTERPRETED?
The Code of conduct has been designed to guide ouractions and help us make decisions in accordance withthe law, our ethical standards and our values.

Nevertheless, the Code of conduct is not intended to be
exhaustive. Neither does it claim to answer all questions
or address all possible cases, particularly with regard towhat you must do and must not do. For this reason, in all
situations and when making decisions, everyone should
ask themselves the following questions:

It explains, by topic, the professional behaviour to befollowed and promoted in carrying out our duties and in
our working relationships.

Is itlegal?

VV

Is it
in the interestof our customers
and stakeholders?

6

A M U N D I / CO D E O F CO ND U CT

Is it in linewith the valuesof theCrédit Agricole Group
Code of Ethics
and Amundi’s Codeof conduct?

Have I taken
into accountthe risks involved
and what theconsequencesof my decision
could be?

V

V

FIVE QUESTIONS TO ASK TO ENSURE ETHICAL BEHAVIOUR

Would I be
comfortable with
my decision if itwere to be madepublic internallyor externally?

If the answer to any of thesequestions is “no”, or if in doubt,
you must discuss it with someone
before taking action. You may
discuss this with your manager,
or contact Compliance, Human
Resources, Corporate Social
Responsibility, Legal or any otherdepartment qualified to deal with
the issue at hand and keep a recordof all problems encountered.

WHO SUPERVISES THE IMPLEMENTATION
OF THE CODE? WHO UPDATES IT?
A multi-disciplinary Compliance/Corporate Social
Responsibility team is responsible for implementing,monitoring and updating the Code of conduct. The Boardof Directors receives a report on this process.
The contents of the Code may change over time. The Codedoes not replace the internal regulations and proceduresof Amundi. It is your duty and responsibility to consult
and apply them.

HOW IS THE CODE OF
CONDUCT MADE AVAILABLE?
The Code of conduct is a documentthat is made public and sharedwith stakeholders. It is available
on Amundi’s website and intranet.

WHAT IS WHISTLEBLOWING?
The aim of the whistleblowing system is to strengthenrisk prevention by giving all internal and external
employees and commercial partners the means to report
the facts that fall within the scope of application of the“whistleblowing” procedure. An internal whistleblowing
procedure designed to collect alert notifications has been
set up.

MANAGER ROLES AND EXPECTATIONS?
As a manager, you must ensure your teams know you arealways there to listen to their needs and create a climateof trust so that they will not hesitate to seek your advice
if they have a problem.
You have to be able to explain to your team how and inwhat areas the Code of conduct applies to their roles.
If you have any questions, don’t hesitate to consult the
department that is most qualified to deal with the issue
at hand (Compliance, Human Resources, etc.).
You must be vigilant, conduct yourself in a transparent
manner, and be an example for your teams. Show that itis entirely possible to attain the objectives that have beenset, while respecting the ethics and values of Amundi and
the Crédit Agricole Group.

WHAT ARE EMPLOYEES’ OBLIGATIONS?
Everyone must familiarise themselves with the principles
set out in the Code of conduct and adhere to them in theperformance of their duties.
In addition, everybody must transmit and promote thevalues and principles presented in the Code of conduct
with vigilance and good intentions.
Moreover, everybody must follow the training programmes
offered on Code of conduct related topics.
One key rule to remember: whenever you notice orsuspect an inappropriate action or form of behaviour, or if
you feel under pressure, you must immediately talk about
it with your manager or the appropriate department.

SCOPE
1. This Code of conduct applies to everyone working forAmundi, in all of its offices in France and abroad;
2. Some specific provisions may be applicable in certain
countries;
3. For more information at the local level, please refer tolocally applicable documents and policies.

Notes:
pp the term “Amundi” refers to all of Amundi Group’s

entities in France and abroad;pp the term “employee” in this document is used in a broad

sense to refer to any person, regardless of their status,
who contributes to Amundi’s activities.

A MU N DI / CODE OF CON D U CT

7

3

Our rulesof conduct

8

A M U N D I / CO D E O F CO ND U CT

E V E R Y DAY E T H I C A L P R AC T I C E

DEFINITION
Ethics falls into the moral scope referring to values,
par ticularly those of the Company. These values
should drive our decisions and our professional
behaviour. Expressed as professional rules of conduct
underpinning our activity, they define our ethicalapproach.

D E TA I L S

ETHICS REFERS TO:COMPLIANCE REFERS

pp Company-specific values formulated as general

to a regulatory environment, with respect for the rules
applicable to financial institutions, as well as to the means
to achieve it via:

concepts (for example, respect for others, solidarity,etc.) and developed into the Company’s “principles ofaction” (for example, combating discrimination);pp the approval and adoption of these values and thisethical framework by the highest level of corporate
governance;
pp a general mission to make known and enforce thevalues, principles and rules of conduct, in such a waythat the ethical framework serves to ensure a feeling of
belonging to the Company, and the trust necessary forlife in the workplace and relations with stakeholders.

While ethics promotes
the respect for values
and rules of conduct.

pp the implementation of internal rules and procedurestransposed into Company laws and regulations;pp the existence of a prescription and control function

performed by a senior manager, which enables theCompany to prevent major non-compliance risks,particularly in regulated business sectors.

The aim of compliance is to prevent infringementsof the ethical framework and of the law in orderto protect the Company against sanctions andany risk to its reputation or brand image.

A MU N DI / CODE OF CON D U CT

9“AC T I N G I N A N E T H I C A L
MANNER” MEANS:
BEING RESPONSIBLE IN OUR
RELATIONS WITH CUSTOMERSAND SUPPLIERS

PREVENTING AND DETECTING
CORRUPTION AND INFLUENCEPEDDLING

All relations must be established in accordance withthe principles of loyalty and solidarity, and with thecommitments made to our customers and suppliers.
Decisions must be made by prioritising customers’interests, respecting the principle of fair and equitablechoice of suppliers and the rules of competition.

The fight against corruption is a major objective related
to the common good and which is based on the values ofhonesty, integrity, loyalty, transparency and impartiality.

RESPECTING INDIVIDUALSWith regard to relations between Company employees orwith any of its stakeholders, human rights and people’s
fundamental social rights must be rigorously applied.
Preventing all forms of discrimination or harassment,
promoting diversity and gender equality, respecting
health and safety measures, and ensuring the protectionof employee and customer data. By respecting theseprinciples we create a favourable working environment,
which is a source of performance and satisfaction.

RESPECTING THE COMPANY’SENVIRONMENTAL AND SOCIETAL
COMMITMENTS
Acting as a responsible financial institution is a corecommitment of Amundi’s development strategy. This
commitment is reflected in our responsible management
and the offer of responsible investment solutions tailoredto our customers’ needs.
As a pioneer in the field of responsible investment,
Amundi has pursued a policy aimed at:
pp integrating Environmental, Social and Governance(ESG) criteria into its management strategies in addition
to traditional financial analysis;
pp undertaking specific initiatives to promote investment

in certain areas, particularly the environment; andpp supporting the social and solidarity economy.

Amundi’s responsibility is also to apply the principles ofsustainable development to its own operations.

10

A M U N D I / CO D E O F CO ND U CT

The anti-corruption component incorporates thefundamental principles of implementing appropriate
measures to prevent, detect and deter corrupt practices
or influence peddling by applying “zero tolerance”. Other
areas include gifts and invitations, facilitation payments,
conflicts of interest, patronage, sponsorship and lobbying.

BEING VIGILANT ON A DAILY BASIS
To maintain trust, we must take responsibility for theuse that can be made of the available resources andinformation in the Company, and guard against any riskof conflicts of interest. We must also ensure that we do
not inappropriately disseminate or exploit, for our own
account or on behalf of a third party, any confidential
information that is held.
The vigilance of all must enable us to protect the interestsof our customers, combat money laundering and thefinancing of terrorism, respect the law on internationalsanctions, combat tax evasion, prevent fraud and protect
the integrity of the market.

ABSTAINING FROM ANY ACTIONS THAT
COULD DAMAGE AMUNDI’S REPUTATION
We are all responsible for Amundi’s image both internallyand externally. The risk of negative publicity, particularlyon the social networks could potentially tarnish Amundi’s
image and erode the trust our customers place in our
Company.
To avoid this risk, we must take care to preserve our
reputation by respecting all the principles set out inthis Code and by refraining from making any remarksthat could commit Amundi, divulging any confidential
information about its professional environment or
participating in spreading rumours.

1

Our rules of conduct
regarding customer
and supplier relations

1.
2.
3.
4.
5.

Customer relationsCustomers’ personal data
Fair and equitable choice of supplier
Responsible supplier relationsCompetition

12
13
14
15
16

A MU N DI / CODE OF CON D U CT

11

1

EXAMPLES?
A major prospective
institutional customer
from a country on the “Do
not deal” list contacted
me to manage a lucrative
mandate. What should I
do?
➞ Before considering any
activity with a new lead,
check with Compliance tomake sure that it is not on
the Crédit Agricole Group’s“Do Not Deal” list. If it is,
you will not be authorised
to provide any services
and must turn down any
proposal.

CUSTOMER
R E L AT I O N S

DEFINITION
Amundi provides individuals, institutional andcorporate clients with innovative savings andinvestment solutions to meet their specificneeds, performance objectives and risk
profiles. The Company places the trust andsatisfaction of its customers at the heart of its
project. Amundi wants all of its employees tobe involved in this relationship while bearing
in mind that the interest of the customer isthe priority in all actions carried out by its
employees, including those who exercise asupport function.

AMUNDI’S COMMITMENT?
After reviewing my
new product proposal,
the CPS issued a
condition. Knowing thatthe client needs this new
product as quickly as
possible, can I still marketit?
➞ No, the CPS process is an
essential mechanism that
ensures customer interests
are protected and avoids
marketing products that
could cause them harm. If
the CPS gives conditional
agreement, the restrictive
clauses thus issued areof a blocking nature. You
cannot, therefore, market the
product or service until all
conditions have been lifted.

As a worldwide asset manager, Amundi is a
responsible institution whose aim is to forge
a global and sustainable relationship with allof its direct and indirect clients (institutions,
corporates, partner networks, distributors andretail investors).
To ensure that its customers’ expectations
are properly fulfilled, Amundi carries out
satisfaction surveys and a range of studies with
its range of customers. Customer complaints
are processed by the competent teams witha view to continually improving our services

I MUST
pp Think through each action to ensure

it is in the interest of customers anddistribution networks and complies
with Amundi’s regulatory framework;and striving for excellence in our customer
relationships. Training is regularly provided to
employees whether or not they are in directcontact with customers. Amundi has alsochosen to be part of Crédit Agricole Group’s
initiative, which periodically measures the
Customer Recommendation Index.
Amundi aims to make a strong commitment
to its institutional customers by adopting aholistic approach to its own corporate issues
and its environment. This in-depth knowledge
underpins our ability to design flexible solutions,shape asset allocations and provide bespoke
advisory services.
Amundi is committed to forging close
relationships with distribution networks andtheir advisory teams, aimed at developing theirexpertise in relation to its products and savings
solutions. Amundi’s teams provide extensive
training to network advisors and help designa wide range of support solutions for advisorsand clients.
Lastly, Amundi’s fundamental commitment
is to be a responsible financial operator in
relation to its customers and this is reflected in
its ambition to integrate Environmental, Socialand Governance (ESG) criteria into all of its
management activities by 2021.

concerning information provided
to customers and ensuring that the
product matches their needs;
pp Report any malfunction or situationthat could lead to a conflict of interest
to your manager.

pp Be attentive to, and get to know

customers better, while respecting theirright to privacy, in order to advise andsupport them appropriately;

pp Always provide customers and network

contacts with clear and accurate
information that is not misleading;pp Be vigilant to prevent all forms of fraud

in order to protect customers, combat
money laundering, the financing ofterrorism, and corruption, etc.;

pp Request that the “New Products &Services Committee” (CPS) approve
all new activities and any changes to
products and services being marketed,to ensure that they comply with legal
and regulatory requirements, notably

12

A M U N D I / CO D E O F CO ND U CT

I MUST NOT
pp Place my personal or Amundi’s interests

before those of our customers;

pp Facilitate, encourage and assist

customers in any actions intended toinfringe laws and regulations;pp Propose a product that has not yet

been authorised by the CPS.

2

C U S TO M E R S ’
P E R S O N A L DATA

EXAMPLES?

DEFINITION

AMUNDI’S COMMITMENT

The Crédit Agricole Group has drawn up a Codeon the use of its customers’ personal data. This
Code provides a reference framework for all
Group employees, including those at Amundi,
in France and abroad, who process this typeof data. It reiterates the commitments madeby the Group as well as best practice to beobserved.

Amundi has taken a firm stance on the sensitive
subject of personal data, by undertaking
to prioritise data security, use data in theinterest of its customers, act in an ethical andresponsible manner, and adopt a transparent
and pedagogical approach towards its
customers so that they can control their data
and the use that is made of it.

I collected the personal dataof my customers, and thendeclared the processing andthe results thereof to the
National Commission for
Data Protection and Liberties(CNIL) before the General Data
Protection Regulation (GDPR)
was put in place. At the time,
we had already received CNIL
approval. Can I still use thesedata?
➞ Under the new regulation
which became effective in
May 2018, you may use orprocess such personal data inaccordance with the declaration
you made. However, the
new regulation requires thatcompanies keep a record of how
data is processed. You mustverify that the characteristics ofthe -approved data processing(as described in the CNIL’s
statement) have been duly
entered in this register. Contact
your DPO if necessary.

?
I would like to use mycustomer database to launcha new product marketing
campaign but I don’t know if
my customers have given theirconsent for their data to be
for this purpose. Do I have theright to do this?

I MUST
pp At the start of an IT project, involve

the Chief Information Security Officer(CISO) and the Data Protection Officer(DPO) to ensure that all personal dataprotection rules are respected;

pp Ensure the project is in keeping withthe principles of the Code: security,
integrity and reliability, ethics,transparency and education, etc.;

pp If in doubt, always contact the CISO or

the DPO.

I MUST NOT
pp Promote a project involving theprocessing of personal data without
having checked with the DPO or the
CISO that the project is compliant;pp Fail to follow the main principles set out

in the Code;pp Process any personal data forunintended purposes or without thecustomer’s prior knowledge;

pp Fail to comply with the rules andrecommendations put in place by
the Crédit Agricole Group to ensure
the security and confidentiality of
personal data, notably by allowing
non‑authorised persons access to thedata.

➞ Even if the data is alreadystored in the customer database,
you may only use it for the
purposes for which it wascollected and only used it for
e-mail campaigns if customers
have given their consent. Check
that you have your customers’
consent to use their data inthis way. Refer to the bestpractices and the guidance oninterpretation presented in the
Crédit Agricole Group’s Personal
Data Code. Ask for advice
from our experts in the Legal,
Compliance and/or IT Security
Departments. In addition, obtain
the express agreement of yourcustomers before issuing any
type of commercial invitation.

A MU N DI / CODE OF CON D U CT

13

3

EXAMPLES?
I heard that duringnegotiating periods, nogifts may be accepted. Is
that right?
➞ Indeed, all gifts (evenof an advertising nature)and invitations must
automatically be refused. In
absolute terms, this meansthat you must not accept
any benefits in kind since this
could distort your judgement
when selecting your supplier.

?
I contacted and met witha company that meets
my needs perfectly. Iteven came up with some
additional proposals. I
decided to forward thedetails of the Company toan Amundi buyer so thatit could be included in thelist of companies to beinterviewed in the context
of a call for tenders. Is thisthe right approach?

FA I R A N D E Q U I TA B L E
CHOICE OF SUPPLIER

DEFINITION

AMUNDI’S COMMITMENT

Choosing a supplier in an equitable and fairmanner above all requires ensuring that allservices providers receive the same treatment
when tender offers are being processed.

For this choice to be fair, all companies mustreceive the same treatment from buyers,
decision-makers and/or any other relevantAmundi employee, and the choice must be
based on objective information.

DETAILS
The equitable choice of supplier must be
made as a result of a fair competition between
bidding companies within the context of acall for tenders. This choice must be basedon objective information that includes socialand environmental responsibility among othercommercial and contractual criteria.

➞ First of all, you have tosummarise what you needthen draft specifications. A
potential supplier cannot
perform this task since they
may be inclined to propose
their solution, tools orservices which might notcorrespond exactly to yourneeds.
➞ You must draw up, withthe help of an Amundibuyer, the list of companies
to be interviewed, andbe supported by a buyer
throughout the interviewing
process (and subsequentpost-interview phases), in
order to find the supplierthat best suits your needs.

I MUST
pp Carefully prepare the list of companies

to be interviewed to ensure that they
have a comparable level of knowledge
and resources (take into account thesize of SMEs compared to large groups
bidding for the same tender);pp Report any potential risk of conflict ofinterest (for example, the existence ofa family member working in one of thebidding companies in calls for tenders,etc.);
companies receive a response withina sufficient and identical time frame.
To ensure this, distribute the tender
documentation once all the bidding
companies have been identified anddo not add any more companies to thelist once the call for tenders has beenlaunched;

pp Ensure that all bidding companies

pp In the event of oral interviews, ensurethat all of the bidding companies areinvited to one or more such sessions.
The duration of the sessions must be
identical for each company interviewed;

A M U N D I / CO D E O F CO ND U CT

pp After completing the first selection

phase and short-listing your preferredbidders, inform the companies notselected of the reasons why they were
not selected;

pp Ensure and respect the confidentialityof the discussions and decisions towhich the decision-makers and theAmundi buyer have access during all
stages of the call for tender process.

pp Make sure that all respondentinterviewed receive the same initial andany modified information, data anddocumentary materials at the sametime (tender terms and conditions,specifications, technical and operating
specifications, contractual obligations,etc.);

14

This involves buyers, decision-makers and/or any other Amundi employees adopting a
responsible and fair attitude to the bidding
companies throughout the duration of thetender process. As such, you should not takepurely individual interests into consideration
when selecting the successful bidder.

I MUST NOT
pp During calls for tenders, provide

information to only some of thecompanies approached;

pp Give any of the bidding companies anindication of the content of the bids or
the level of response of the othercompanies participating in the call for
tenders;

pp Change the selection criteria, and/or

the ranking weighting, after the dateof receipt of the replies to the call for
tenders;

pp Accept any invitations, gifts or benefits

in kind from one or more of the bidding
companies during the call for tender orthe contractual negotiations.

4

RESPONSIBLES U P P L I E R R E L AT I O N S

DEFINITION

EXAMPLES?

pp financial equality: remunerating suppliers

Reasonable due diligence is necessary toensure that all actors in the procurement
process act in accordance with a certain
number of commitments and principles,notably concerning respecting human rights
and fundamental freedoms, complying withworkplace regulations, combating all forms of
discrimination, the promotion of diversity andthe protection of the environment and businessethics. Failure by any player in the supply chain
to act in accordance with these commitments
and principles could seriously impair Amundi’s
performance, reputation or image.

in accordance with applicable laws andregulations;pp equal treatment;
pp transparency of our processes;
pp promoting sustainable relationships;
pp preventing corruption, by adhering torules known to suppliers;
pp conducting a comprehensive cost analysisof all costs incurred over the lifetime of
the goods or services;
pp integratingsocial and environment
performance in supplier selection criteria;

pp promoting the regions by choosing local

suppliers when appropriate.

AMUNDI’S COMMITMENT
The commitments and principles of Amundi
are in line with those of the Crédit Agricole
Group. These notably include:

The diversity of these commitments andprinciples applies not only to buyers but toall Amundi employees who have establisheda business relationship with a supplier.

I want to launch a call for
tenders and have five days
to choose a supplier: Is thispossible?
➞ Suppliers need a minimum
time to respond. This time isnecessary so that suppliers canprepare a relevant and complete
response.

?
I want to work with asupplier with whom I am
entirely satisfied. I have beenworking with this supplierfor 10 years now and almost
all of its revenue comes from
Amundi. Is there a risk?
➞ In order to assess this risk, thebuyer must analyse the financial
health and the service provider’s
degree of economic dependency
and propose alternative solutions
if the level of dependency
exceeds 25%. Should the service
come to an abrupt halt, therisk incurred could be financial,
operational or legal.

?
I MUST

I MUST NOT

pp Behave honestly in dealings withpp Incur expenses with a supplier on

pp Involve a buyer who is positioned

pp During discussions with a supplier,

pp Leave it to the buyer to inform thepp Fail to carry out a preliminary analysis

suppliers so as to forge a bond of trust,whether the relationship is one-off orlong-term;
sufficiently upstream in order toguarantee the entire purchasing process
and to manage risks, particularly at thelegal, financial and operational level;companies (bidders) that have notbeen selected as a result of the call for
tender and to provide objective criteria
justifying this decision;

pp Compare the offers submitted by the

suppliers interviewed, on all of theselection criteria, by factoring in theoverall cost;

pp When changing supplier, provide a

reasonable period of notice in order togive the former supplier a viable andacceptable withdrawal period;

pp Provide all of the information needed

to approve invoices and thereby help
meet the payment deadlines set byregulations.

behalf of Amundi without receiving
formal authorization to do so (seedelegation of powers);
disclose and supply any information
related to Amundi’s strategy or any
other sensitive data that would not be
publicly available;

I want to replace a services
provider and terminate its
contract before it expires?
➞ The buyer will indicate theperiod of notice to be respected
and, depending on the supplier’s
level of dependency andthe duration of its business
relationship with Amundi,
propose exit conditions thatwill allow the service provider
to maintain its financial stability
while it reorganises its business.

of the financial health of a supplierduring the selection process or take
into account all the criteria that could
lead to its becoming economicallydependent at the beginning andthroughout its business relationshipwith Amundi;

pp Validate the receipt of services without

following up supplier invoice processing
and payment and, in particular,
compliance with payment deadlines set
by regulations;pp Terminate a contract without giving

sufficient notice enabling the supplier
to reorganize its business.

A MU N DI / CODE OF CON D U CT

15

5EXAMPLES?

COMPETITION

I sometimes haveto participate on
Amundi’s behalf inmeetings or discussions
within a professional
association. Which
topics do I have the rightto discuss and what
provisions should I take?

DEFINITION➞ You can discuss various
topics and coordinate certain
actions with competitors,
provided that these do not
relate to subjects deemedsensitive.

DETAILS➞ Remember that
attending (even passively)a meeting where thetopic could be qualified asanti- competitive may beconsidered as membershipof a cartel. Before attending
any such meetings, makesure there is an agenda. In
the event of non-compliancewith competition rules, leave
the meeting and request thatyour departure be noted in
the minutes. Do not hesitate
to seek help from the Legal
Department to find out what
attitude should be adopted
before, during and after suchmeetings.

Competition law consists of a set of rules
applicable to both private and public
enterprises operating in different markets. Its
purpose is to maintain the principle of free
and fair competition and to ensure consumer
protection.

Abuse of a dominant position concerns
companies in a position to act unilaterally
in a given market: pricing policies aimed
at eliminating competitors or commercial
foreclosure strategies and discriminatory
practices, etc.

AMUNDI’S COMMITMENT
Many types of behaviour, such as cartels andabuse of dominance, can jeopardise freecompetition.
A cartel is an agreement, concerted
behaviour or a planned and intentional
collaboration between companies whose
purpose or effect, even potentially, is tocoordinate their behaviour in order to limit
competition. An agreement with a company,
be it a competitor or not, may take theform of an oral, written, formal or informal
agreement (during a business lunch, or at a
trade association event, etc.).
In addition to the most serious forms ofcartel agreements (such as the joint fixingof sales prices or commercial conditions),
the distribution of customers or markets,coordination of tenders or a decision to
boycott a particular customer or supplier,also constitute a cartel.

All Amundi activities must be carriedout in compliance with competition law,
the fundamental principle being thatcompanies operating in a market must
determine their strategy in an autonomous
manner. Agreements between independentcompanies and abuses of dominant position
are therefore strictly prohibited.
Sensitive information is non-public datathat might be useful in strategic terms
such as information on prices and trends,
list of customers, market capacity anddistribution methods, strategy and costs,
etc.. It is nevertheless possible for some
information to be shared with Amundi’s
competitors once this information has been
made public, if it relates to a topic of generalinterest for the profession or if it is within theframework of trade associations. In this case,the information must be aggregated and not
be able to be separated out (statistics, etc.).

?
I am representing Amundi
within the context of its
participation in a banking
or investment pool: what
precautions should I take?
➞ Recourse to the poolmust be justified by thenature of the transaction
and the objective reasons,notably in terms of risk
sharing. Coordination
between the operators must
be strictly limited to theoperation for which the pool
was established. Ensure thatthe coordination activity
never deviates from thetransaction in question andthat this is recorded in thenotes of the meetings.

I MUST
pp Avoid addressing sensitive issues wheninteracting with third parties outside
the Crédit Agricole Group, regardless ofthe context;

pp If such topics are brought up, terminate

the conversation and immediately
notify your manager and the Legal
Department;

pp If in doubt about the degree ofsensitivity of the information, checkwith your Legal manager before
undertaking discussions with acompetitor or trade association;

pp In the context of formal and necessary

relations with competitors, clearly
indicate the purpose of the exchange,
limit the discussion strictly to its
purpose and keep a written record;

pp Contact the Legal Department before

entering into any agreement likely tohave a significant competitive effect on
the market concerned.

16

A M U N D I / CO D E O F CO ND U CT

I MUST NOT
pp Consult with any competitor or

exchange information with them on theprices of services or customer prices;

pp Conclude any customer, territory

or market sharing agreements withcompetitors;

pp Boycott certain customers or suppliers;
pp Negotiate clauses such as those limiting

the commercial freedom of trading
partners without seeking advice fromthe Legal Department.

Our rules of conduct
regarding social, environmental
and societal issues
6. Protection of employees’ data
7. Health and safety at work
8. Non-discrimination
9. Diversity and gender equality
10. Combating harassment
11. Extraprofessional activities
12. Environmental strategy

18
19
20
21
22
23
24

A MU N DI / CODE OF CON D U CT

17

6

EXAMPLE?
As part of my duties as a
HR Manager, I have accessto the personal data ofthe employees in my areaof management. I didn’t
have enough time to finish
my work and copied apart of it onto my USB
key so that I could do it athome. Unfortunately, I lost
my USB key on the train
back home. Should I notify
someone?
➞ You must report theloss to your manager
and to Amundi’s Chief
Information Security
Officer (CISO) who will
inform the Data Protection
Officer (DPO). The loss of
this USB key could haveserious consequences andcause significant damage,both to the Company andemployees.

PROTECTIONO F E M P L OY E E S ’ DATADEFINITION
Everyone has the right to have their privacy
respected. Personal data may only be collected,
processed and stored for specific and legitimate
purposes. This information must be brought tothe attention of all employees.

AMUNDI’S COMMITMENTDETAILS
The use of data is strictly controlled:
pp only data that is relevant and necessary

with regard to the targeted objectives,
which must have been clearly defined inadvance, should be processed;
pp personal data must not be stored for an

unlimited period of time;
pp the necessary measures must be taken

to guarantee data confidentiality and to
avoid any communication to unauthorised
third parties;
pp everyone must be informed about the➞ Never copy any personal
data either onto an external
device or your computer. In
cases of utmost necessity,
only use secure USB keys
provided by Amundi andprotect the files stored
on your computer with apassword if the data is notencrypted. To ensure thesecurity of personal data,
it is essential to respect
the internal rules andprocedures.

I MUSTAs an employer, Amundi has drawn up an
Employee Charter which guarantees employees
the protection of their personal data and theirright to privacy.

I MUST NOT

pp Ensure the appropriateness andpp Collect personal information that does

pp Ensure the lawfulness, integrity andpp Communicate people’s personal data totransparency of employee dataprocessing;pp When necessary, ensure that the way

personal data is used is entered into thepersonal data processing register;

not match a specific and necessary use;
any unauthorised third parties, whether
internal or external, without theirexpress consent;

pp Conserve personal data without any

authorisation;

pp Inform employees about how the

pp Conserve data beyond the planned

pp Guarantee employees’ right to privacy

pp Copy data onto any form of

personal data they have given is used;notably by not transmitting theirinformation to unauthorised persons
and ensuring personal data are kept
securely;

pp Request that all inaccurate or

incomplete data be completed or
removed;pp In the event of subcontracting, ensurethat services providers respect thesesame principles.

A M U N D I / CO D E O F CO ND U CT

In a context where everyone communicates
their personal data in a paperless form, theCrédit Agricole Group has drawn up a charter
based on five principles: integrity and reliability,
ethics, transparency and education, security
and customer control over the use of their data.
This charter provides a reference framework
for all Group employees, including those at
Amundi, both in France and abroad.

processing of any of their personal data.
They also have the right to access andmodify their information, and may oppose
the processing thereof for legitimate
reasons.

relevance of the information collected;

18

The destruction, loss, alteration, disclosure or
unauthorised access to personal data may
infringe upon the rights of individuals, as wellas the individual and collective liberties of
employees. Internal rules and procedures must
therefore be respected.

retention period;

unprotected media and take it out of
the Company.

7

H E A LT H A N D S A F E T Y
AT WO R K

EXAMPLES?

DEFINITION

AMUNDI’S COMMITMENT

Companies must take the necessary steps toensure the safety and protect the physicaland mental health of their employees. These
measures notably include implementing astrategy to prevent occupational risks as wellas carrying out information campaigns andtraining sessions.

Everyone working for, or with, Amundi must
be able to do so in a secure, collaborativeand respectful working environment. Amundi
endeavours to take all the necessary measures
to ensure the safety and protect the physicaland mental health of its employees.
However, safety in the workplace also depends
on all of us. All Company employees must takecare, in accordance with their training and thebest of their abilities, of their own safety andhealth, and that of other people affected bytheir acts or omissions at work.

I’ve noticed a change inbehaviour of a colleague ofmine: he seems very stressed,
isolates himself, has lunchedalone for some time andrefuses to discuss anything. It
worries me but I don’t knowwhat I can do.
➞ This situation troubles
you. It is important to share
this information with yourmanager, the Human Resources
Department or the Occupational
Health Department so that they
can intervene rapidly in theinterests, and for the good of theperson concerned.

?
During the last fire drill, I
realised that the two people
responsible for evacuating myunit were both absent; onecolleague didn’t know what todo. Should I notify someone?
➞ During the drill, you noticed aglitch in the drill procedure. That
could have compromised thesafety of a colleague. You must
inform the security officer inwriting, so that she or he canrectify the situation and take thenecessary measures to ensure
the security of all persons on thesite.

I MUST
pp Become acquainted with andrespect Amundi’s health and security
regulations;pp Make sure that my actions and conduct

present no risks to me or for otherpeople;I MUST NOT
pp Ignore Amundi’s rules on health andsafety in the workplace;pp Ignore any situation that could

compromise the safety and security of
our working environment.

pp Contribute to safety and security inthe workplace. This notably involves
participating in safety drills andtraining programmes organised by theCompany and reporting any situationthat could constitute a risk to security
and safety in the workplace to the
Human Resources Department.

A MU N DI / CODE OF CON D U CT

19

8

EXAMPLES?
The HR Department wants
me to integrate a disabled
person into my team. Can
I approach the issueof disability during theinterview?
➞ Questions related tothe origin and nature of
an individual’s disability
cannot be raised since thisinformation is covered by
the person’s right to medical
confidentiality. Nonetheless,if candidates wish totalk about their personal
situation, questions should
be focused on elements thatwill have a direct impact on
the performance of theirprofessional activity.

N O N - D I S C R I M I N AT I O N

DEFINITION
Discrimination is the act of treating someone
less favourably than another on the basisof certain criterion and characteristics, inparticular:
pp age;pp belonging to an ethnic group, nationality

or presumed race;
pp family situation or pregnancy;
pp genetic characteristics;
pp disability, loss of autonomy;
pp state of health;pp surname, first name;pp origin;pp place of residence;

I overheard a colleague
referring to anothercolleague using racist
language. What should I
do?
➞ You can say something
directly to your colleague if
you are comfortable doingso, but in any case you
should contact your manager
and/or the Human Resources
Department. It may be easier
to look the other way, but
we all have a responsibility
to create and maintain arespectful and collaborative
working environment.

pp political opinions;
pp religion;
pp sexual orientation or customs;
pp trade union activities or views;
pp v u l n e ra b i l i t yre s u l t i n g f ro m t h e i rsocioeconomic situation that is clear or
known to its author; or

pp any other perceived difference.

I MUST
pp Reject all forms of discrimination

directed at employees, clients,
suppliers, service providers and otherindividuals having dealings with
Amundi;pp Not accept any practice or behaviour

that would or could be discriminatory
against employees, suppliers,
customers, etc.;

pp Provide support to, and talk to

the victim of discrimination and,if necessary, alert my manager orthe Human Resources Department;

pp If I am a manager, be careful to base mydecisions on objective criteria and do
not have any prejudices.

20

Indirect discrimination refers to any practicethat although seemingly neutral, puts an
individual at a disadvantage vis-à-vis others
because of their sex, age, a disability or othercharacteristic.

pp gender identity;

pp physical appearance;?

Discrimination may be direct or indirect.
Direct discrimination refers to any practiceleading to unfair treatment related to
employment, training, promotion or any
other aspect of working life.

A M U N D I / CO D E O F CO ND U CT

AMUNDI’S COMMITMENT
Amundi is a diverse company which believes
that ensuring integration, revealing talent andencouraging the diversity of all employees,
are key driving forces underpinning theCompany’s development. This conviction
and compliance with the principle of equal
opportunities are the underlying principles
that form the foundation of all our HR
actions. Amundi considers that all forms of
discriminatory behaviour are unacceptableand deprive people of the respect due
to them. To combat stereotypes andthwart decision-making bias, Amundi iscommitted to raising the awareness of its
directors, managers and employees to nondiscrimination issues.

I MUST NOT
pp Participate in any form of

discrimination;

pp Contribute to creating a hostile climatethat is conducive to discrimination.

9

DIVERSITY AND
G E N D E R E Q UA L I T Y

EXAMPLES?

DEFINITION

AMUNDI’S COMMITMENT

The Company’s corporate diversity policy isbased on a set of principles and actions that,by way of a proactive approach, are aimed atdeveloping and promoting a variety of profiles.

Amundi is a diverse company which believes
that ensuring integration, revealing talent andencouraging the diversity of all employees, are
key driving forces underpinning the Company’s
development. Promoting gender diversity
is about creating an open and responsible
corporate culture that fosters internal cohesion
and progress. This commitment is reflected inconcrete actions, such as studies carried out
to measure the pay gap between women andmen, compensating employees to reduce
unjustified pay differences and recruiting
people with disabilities.

Depending on the national regulations in force,companies may be required to comply withobligations such as gender equality or theemployment of people with disabilities.

Most of the people in my teamare men. One of my staff isretiring in a few weeks andI’m thinking about replacing
them with someone in theteam. Should I focus onpromoting a woman?
➞ Above all, base yourjudgement on the skills of
everybody in your team andchoose the person best suited tofulfil the duties of the job.

?
I have received several
applications for a vacant
position on my team. After
carrying out several interviews,
the person whose skills
are most in line with thejob requirements has adisability. How will my teamreact?
➞ It is essential to rememberthat a person’s skills are the only
factor to be taken into accountwhen recruiting. As a manager, if
you have any concerns about thesuccessful integration of this new
employee into your team, do nothesitate to consult your Human
Resources contact. If necessary,
actions may be implemented toensure that the integration of the
new employee into your team iscarried out in the best possibleway.

I MUST

I MUST NOT

pp Make objective judgement focused on

pp Make a decision based on non-objective

pp Obtain different opinions to ensure

pp Implement processes that canskills in all managerial decisions;objectivity;

pp Promote diversity in my teams.

criteria;

lead to unequal treatment or evendiscrimination.

A MU N DI / CODE OF CON D U CT

21

10

EXAMPLES?
A colleague is particularly
intimidating and likes
to humiliate people. He
frequently makes
sexual innuendos andinappropriate gestures
towards me. Despite myinsistence that he stop thisbehaviour, he continues topester me for a date.
➞ Report this immediately
to your manager, Human
Resources Department ordesignated local contact inorder to alert them to thisunacceptable behaviour.

?
A colleague of mine isrepeatedly being subject,in a humiliating way, tocriticism of their work andbeing reproached in frontof the rest of the team.
They are taking more andmore time off for sickleave.
➞ Notify your manager,
Human Resources contact
or designated local contact
without delay who will takeaction to put an end to theharassment.

C O M B AT I N G
HARASSMENT

DEFINITION

AMUNDI’S COMMITMENT

Harassment is defined as any unwanted or
unsolicited behaviour or conduct directed
towards an individual (or group of individuals)
which, by its severity and/or perseverance,
is likely to create a hostile or intimidating
environment and to negatively impact thetargeted individual’s involvement in theirwork. Harassment can be “moral” and takethe form of derogatory remarks, humiliation,bullying, intimidation or insults. Sexual
harassment is the act of repeatedly making
sexual comments towards or imposing
behaviour of sexual nature on an individualthat undermine their dignity because of
the degrading or humiliating nature of the
behaviour or that creates an intimidating,hostile or offensive environment.

Amundi considers that any behaviour or actionthat may violate an individual’s right to respectand human dignity and notably any form of
moral or sexual harassment, sexist activity or
violence at work are unacceptable.

I MUST

I MUST NOT

pp Respect others;
pp Find out about the Company’s internal

prevention and action policies andprocedures;

pp Be attentive to everything and everyone

around me, contact my manager, Human
Resources or designated local contact, if
I am aware of harassment cases.

Amundi is committed to preventing, detecting
and resolving such actions which are offencesthat are heavily sanctioned. Any employee may
call upon their manager, the Human Resources
Department and local points of contacts, if
necessary.
No employee, trainee or intern may besanctioned, dismissed or discriminated against
for having suffered or refused to accept sexual
harassment or acts of moral harassment or for
testifying about such acts.

pp Ignore a situation of harassment that I

know about, whether I am the victim ora witness, irrespective of the reason(s)or the alleged ramification(s);pp Behave in a way that I know is

undesirable.

WHOM SHOULD I CONTACT?
If you are confronted with a situationthat involves sexual / moral
harassment, sexism or violence atwork, tell your manager, your Human
Resources Department or any otherdesignated local contact.

22

A M U N D I / CO D E O F CO ND U CT

Notifications can be made in writingor verbally (depending on the
country) and will be treated in thestrictest confidentiality.
Depending on the regulations
in force in some countries, youmust contact the appropriate
representative, who may be a person
outside Amundi.

11

EXTRAPROFESSIONAL
AC T I V I T I E S

EXAMPLE?

DEFINITIONDETAILS

An extraprofessional activity is an activity thatyou undertake outside your working hours. The
concept of multi-activity can be defined as thesimultaneous exercise by the same person of
two or more activities of a professional, tradeunion or political nature.

Having a salaried job does not prevent you
from having an independent or self-employed
activity at the same time. Accumulation ofactivities is possible since salaried jobs are
the only activity that is subject to working
time regulations. It follows, for example, that
employees can, for example, carry out work fora non-profit organization.

I am being asked to join
an investment advisory
association, can I respondpositively?
➞ You must inform your manager
and send your request to theCompliance Department sothat it can assess any potential
conflicts of interest. You may be
asked to decline this request.

However, while the principle is the freedom towork, employees must respect a professional
Code of Ethics with respect to their employers.
Indeed, for the duration of their employment,
an employee is bound by an obligation of
loyalty towards Amundi. In general, thisobligation involves taking care not to tarnish the
reputation or prevent the proper functioningof the Company, notably by disparaging theCompany or undertaking competitive practices
that would be against its interests.

I MUST

I MUST NOT

pp Inform my manager and the Humanpp Exercise an activity that competes withpp If necessary, declare this activity to the

pp Perform an extraprofessional activity

Resources Department beforehand,
and when any changes occur, that
I intend to perform a paid activity
outside my working hours (excluding
the production of scientific, literary andartistic works);
Compliance manager;

pp Respect the obligations ofconfidentiality, professional secrecy andtrade secrets;

pp Be well acquainted with the terms of

my employment contract in order toapply the clauses that I am required torespect. If necessary, ask the Human
Resources Department to explain it tome.

that of the Company during the termof my employment contract (including
using a period of leave to perform a
remunerated activity or training periodwith a company, regardless of whether
it is a competitor);in addition to my professional activity,that could prevent me from achieving
the objectives defined in the context
of my salaried activity, or generate
conflicts of interest;

pp Exercise any extraprofessional activity

during the working hours defined in mycontract;

pp Use the work equipment andresources put at my disposal for my
extraprofessional activities.

A MU N DI / CODE OF CON D U CT

23

12

EXAMPLE?
I do not see why we’reconcerned with theenvironment. We’re not an
industrial company thathas factories.
➞ Amundi’s operations
do not have a major
direct environmental
impact. Nevertheless, weare aware that it is ourduty as sector leader to
set an example, and theCompany strives to apply
the principles of social
responsibility to its own
corporate processes. Amundi
is therefore committed toreducing its impact on theenvironment by controlling
its CO2 emissions throughactively managing its energy
consumption and businesstravel, taking environmental
action for the responsible
use of paper and recycling
its waste, raising employee
awareness to “eco-gestures”
and developing green IT.

E N V I R O N M E N TA L
S T R AT E G Y

DEFINITION

AMUNDI’S COMMITMENT

Corporate Social Responsibility is defined as
being the responsibility of companies withregard to the effects they have on society
and, more specifically, how they intentionallyintegrate social and environmental concerns intheir business operations and in their interaction
with their stakeholders.

Amundi takes account of combating climatechange and of the energy transition in its
business and corporate processes. In thisregard, it has two principle objectives:
D eve l o p i n g g re e n i nve st m e n t s a n d
supporting clients to help them meet theirenvironmental challenges, by:
pp offering investment solutions and services

that have an environmental dimension;

DETAILS

pp integrating environmental risk into issuers’

Businesses must contribute to sustainable
development, including the health and wellbeing of society. For this, they must commit to:
pp takinginto account stakeholders’expectations;pp fully meeting legal obligations or evengoing beyond them;
pp investing more in human capital and theenvironment;
pp integrating this responsibility across theorganisation and implementing it in all
internal and external relations.

non-financial ratings;
pp stepping up the promotion of investments

in projects and initiatives designed tocombat climate change and support theenergy transition.
Reducing its direct environmental footprint:
pp byconstantly improving the ecoefficiency of its buildings;

pp by preserving resources;
pp by reducing its energy consumption andits direct carbon footprint;
pp by

reducing the amount of waste
produced by its sites and by improving
waste recycling;

pp b yincorporating environmental
requirements into its supplier-selection
criteria.

I MUST
pp Be aware of the daily impact of mybehaviour on the environment;

pp Take personal responsibility andtake into consideration the direct
and indirect environmental impacts
generated by my professional activity;

pp Undertake to contribute to Amundi’s

environmental objectives and actions,particularly in discussions withcustomers and stakeholders and when
speaking outside of the Company.

24

A M U N D I / CO D E O F CO ND U CT

I MUST NOT
pp Ignore Amundi’s environmental

objectives and commitments.

Our rules of conduct
regarding anti-corruption

13. Fight against bribery
26
14. Fight against influence peddlingand interaction with public officials
27
15. Fight against facilitation payments28
16. Conflicts of interest
29
17. Gifts and invitations30
18. Lobbying and financing political parties
31
19. Patronage and charitable actions32
20. Sponsorship33

A MU N DI / CODE OF CON D U CT

25

13

EXAMPLES?
One of my suppliers isoffering me a weekend
by the sea. In exchange, I
simply need to reduce thetime it takes to pay my
invoices by a few weeks.
Can I do it?
➞ It is prohibited to takeadvantage of your position
or duties to receive gifts
or benefits. Alert yourmanager, your ComplianceDepartment and thePurchasing Department
immediately regarding thisattempt bribery.

?
A contact with whom
I have a very good
relationship has invited
me to a trade show on theother side of the world;
they have also offered to
pay for part of the trip.
What should I do?

F I G H T AG A I N S T
BRIBERY

DEFINITION
Bribery is an act of an individual in a specificpublic or private function who solicits, offers,
gives or accepts a fee, gift, promise, or any
other undue advantage in order to perform,
delay or omit to perform an act which is,directly or indirectly, within the sphere of theirduties.

DETAILS
In French law, a distinction is made between
the offence of active bribery initiated by thecorruptor, and the offence of passive bribery
initiated by the corrupt.
Active bribery is the deliberate act of making,either directly or indirectly, offers, promises,
donations, gifts or any other advantage to
public officials or private persons in order thatthey perform or refrain from performing an act
within the scope of their duties.
Passive bribery concerns public officials or
private persons who solicit or authorize,➞ Politely decline thisoffer. To preserve theindependence of Amundi
and its employees, it is notpossible to have all or part ofa trip, even a business trip,
paid by a third party.
➞ On the other hand, if all
the costs are covered by
Amundi, you can participate
in this trade fair without
being indebted to thecontact.

I MUST DO
pp In order to effectively fight against

bribery, proven cases or attempts,
whether internal or external, must
be reported as soon as possible andas soon as they are identified, to
my manager and the ComplianceDepartment of my entity;

pp Declare internally all gifts and benefits?
My manager asks me tosuggest to one of ourusual external service
providers that they hire
one of the manager’s
children. What should I do?
➞ Politely state therequest and refer it to yourmanager’s line manager.

offered or received, in accordancewith the provisions pre-establishedby Amundi (see 17. GIFTS AND
INVITATIONS);

pp Comply with existing procedures

directly or indirectly, promises, donations, gifts,
or any advantages for themselves or for others,in order to perform or refrain from performing
an act within the scope of their duties.
Bribery can be internal (involving only
employees of Amundi) or external (involving
persons or entities outside Amundi).
Any act of bribery can exposed to imprisonment
and/or financial penalties.

AMUNDI’S COMMITMENT
Our anti-bribery policy is simple. Employees
are strictly prohibited from engaging in acts ofbribery, regardless of the form or reason.
Corruption hinders free competition andhinders economic development; it can havevery serious financial, commercial and criminal
consequences, which can seriously damage
Amundi reputation and its image. Employees
who participate actively in an act of corruption,
may also be exposed, in their personal capacity,
to disciplinary and even criminal sanctions.

I MUST NOT DO
pp Offer, promise or agree to giving abenefit (financial or otherwise) to a third
party, for the purposes of inducing themto improperly perform or refrain fromperforming an act;

pp Solicit, receive or accept any benefits(financial or otherwise) in exchange for
performing a task, give consent under acommercial agreement or carry out anyother action in the course of your duties
or activities;

pp Favour a third party in the context of acall for tenders;

for approving expenses incurred by
employees;

pp Offer or accept gifts and benefits others

pp Be constantly on the alert and monitor

pp Allow all or part of a trip to be paid for

relations with intermediaries andsuppliers;

pp Comply with the recruitment policies

defined by Amundi;

pp Ensure that all payments are properly

justified, documented and authorized.

than those authorized;

by a third party, including business trips;

pp Favor a supplier or service provider

on the basis of non-objective criteria(prices, services, quality, reputation,etc.), outside of the Crédit Agricole
Group’s purchasing policy, for personalreasons (friends, family, etc.);

pp Hide or conceal elements of corruption

or acts likely to constitute it from amanager or supervisor, in charge of aninternal or external audit, or from anaudit body.

26

A M U N D I / CO D E O F CO ND U CT

14

F I G H T AG A I N S T
INFLUENCE PEDDLINGA N D I N T E R AC T I O N
W ITH P UBLIC OFFI C I A LS

DEFINITION
Influence peddling is the act of persons in aposition of public authority or entrusted witha public services mission, or elected officials,
who solicit or illegally accept offers, promises,
donations, presents or benefits of any kindfor themselves or for others, with the aim ofusing their real or supposed influence to obtainawards, jobs, markets or any other positive
decision from a public authority or public
administration.

DETAILS
Influence peddling is the act of monetizing
someone’s position or actual or supposed
influence in order to influence a decision
to be made by a third party. This involves
three parties: the beneficiary (who provides
the benefits or makes the donations), theintermediary (who uses the credit he has
because of his position) and the target person,

I MUST
pp In order to combat influence peddling,effectively, whether proven cases or
attempts, internal or external, report itas soon as possible when you detect it,
to your manager and your ComplianceDepartment;

pp Comply with the procedures for

activities involving public officials;

pp Be constantly on the alert and regularly

monitor all transactions involving public
officials;

who holds the decision-making power (publicauthority or administration, magistrate, expert,etc.).
There is a distinction between active influencepeddling, concerning the beneficiary, andpassive influence peddling, concerning theintermediary. Each of the two offences istreated separately and may be punishable byimprisonment.

AMUNDI’S COMMITMENTS

EXAMPLES?
To open a subsidiary in aforeign country, we mustobtain a specific approval. An
employee of a government
department in this country
proposes to influence theperson in charge of granting
the approval and offers to pay
part of the requested amountinto a bank account. Whatshould I do?
➞ Refuse and notify yourmanager as soon as possible
and seek advice from yourCompliance manager toavoid becoming involved in a
corruption process.

?

Our policy is simple, it is strictly forbidden for
employees to engage in any influence peddling,whatever the form or reason.
All employees must conduct their business inaccordance with the anti-corruption regulations
applicable in the countries in which we operate.
Gifts, benefits or public relations activities
offered to public officials are strictly prohibited.
Some activities involving public officials requireparticular vigilance.

In the context of a real estate
project, a representative ofthe town hall asks that in
exchange for the support ofan application for a building
permit for Amundi, thatan apartment of the futurebuilding be reserved for amember of his family.
➞ Refuse and notify yourmanager and your Compliancemanager as soon as possible
who will take appropriate
measures to report this action
to the municipal authority. No
consideration may be offered toa public official in exchange fora favor.

I MUST NOT
pp Offer, promise or consent to giving

a benefit (financial or otherwise) toa public official, for the purposes of
inducing them to improperly perform or
refrain from performing an act;

pp Favour a relative of a public official

within the context of a call for tenders
or a recruitment process;pp Give cash to public officials.

pp Ensure that all payments and expenses

involving public officials are properly
authorized, accounted for anddocumented.

A MU N DI / CODE OF CON D U CT

27

15

EXAMPLES?
In order to obtain apermit as part of thedevelopment of a realestate construction
programme for Amundi, an
official offered to speed up
the process of obtaining
a permit, which usuallytakes several months, inexchange for a bonus. Do I
have to pay?
➞ No, because this amount
not legitimate expense.
Inform your manager orCompliance Officer as
facilitation payments can beconsidered corrupt.

?
I have to travel onbusiness to a country forwhich I need a visa. At
the embassy, the officer
informed me that thetime it takes to obtain thevisa is longer than I had
expected. He suggests that
I speed up the process if I
pay him the sum of €1,000.
What should I do?

F I G H T AG A I N S T
FAC I L I TAT I O N
PAYMENTS

DEFINITION

AMUNDI’S COMMITMENT

Facilitation payments are small payments madedirectly or indirectly to civil servants and/or
public officials to expedite or guarantee, in thenormal course of business, the performance ofa routine action to which the payer is entitled.
These payments are made in particular inconnection with processing a visa application,issuing an authorisation, permit or licence or
customs formalities.

Facilitation payments are strictly forbidden.
Only in exceptional cases, particularly where
the security or physical safety of an employee
is threatened, can exceptions be made. In suchsituations, the Compliance manager should
be notified as soon as possible. In addition,
facilitation payments must be properly
identified and recorded in the Company’s
accounting records and documents.

DETAILS
These payments are considered to be acts ofcorruption. They are prohibited by the OECD
Convention on Combating Bribery of Foreign
Public Officials in International BusinessTransactions of 17 December 1997.

➞ To avoid any act of
corruption, politely decline
this offer and inform yourmanager or the Compliancemanager without delay.

I MUST
pp Consult my manager or the Compliance

pp Offer, promise or give a benefit

pp Alert my manager or the Compliance

pp Mediate on my own when dealing withmanager if I receive a request for a
facilitation payment from a public
official;

manager if, in the context of an
exceptional situation, I have made atransaction that may be considered afacilitation payment;

pp Keep all documents relating to anytransaction that could be considered afacilitation payment.

28

A M U N D I / CO D E O F CO ND U CT

I MUST NOT(financial or otherwise) to a public
official within the context of performinga routine administrative task;a facilitation payment request.

16

CO N F L I C T S
OF INTEREST

EXAMPLES?

DEFINITIONDETAILS

A conflict of interests is a situation in which an
employee’s personal interests may conflict withthose of client or an entity.

Financial institutions must formally supervise
the management of conflicts of interest that
may arise in the course of their activities. To thisend, they must maintain and enforce effective
organizational arrangements, with a view totaking all reasonable measures to prevent
conflicts of interest from affecting the interestsof their clients. Respect for the primacy ofclients’ interests is an essential element inmanaging conflicts of interest.

In other words, a conflict of interests is any
professional situation in which the discretion ordecision-making power of a person, company
or organization may be influenced or altered,in terms of its independence or integrity, by
personal considerations or under pressure froma third party.
Conflicts of interest include those of a personal,
professional, financial and political nature.

AMUNDI’S COMMITMENT
In accordance with the Crédit Agricole Group’s
regulatory requirements and procedures,
Amundi has chosen to implement a system toprevent and manage conflicts of interest. Thesemaybe acts of corruption or influence peddlingand expose the Company and its employees
to accusations of bias or dishonesty. They canalso have consequences on the reputation andimage of Amundi and its employees.

I MUST
pp Respect Amundi’s prevention principles

and measures notably regarding gifts
and benefits, public relations activities
and extra-professional activities, toensure I maintain my independenceof judgement and avoid situations ofconflicts of interest;

pp Declare my elected public offices to mymanager and Compliance manager;

My manager asks me for my
opinion on choosing a new
supplier because he hesitates
between two companies. It
turns out that the director of
one of the companies is one of
my childhood friends. What is
the right attitude to adopt?
➞ To avoid any conflicts ofinterest, inform your manager inwriting of this relationship andwithdraw from the selection
process.

?
My brother is a service
provider in a training
organisation, and the offers
he offers are competitive andmatch our needs. Should I
avoid using it?
➞ Report this situation in writing
to your manager, who shouldtake all necessary measures
to avoid a possible conflict ofinterest. In particular, do nottake part in choosing the service
provider.

I MUST NOT
pp Make decisions if my discretion ordecisions could be influenced or alteredby personal considerations or bypressures imposed by a third party;

pp Conceal information about any conflictof interests or situations that could
create such a situation;

pp Acquire positions of interest in acompetitor, customer or supplier.

pp Declare to my manager and

my Compliance manager theadministrative, management or
executive responsibilities that I holdon a private basis in any for-profit
organization (client, Amundi supplier,etc.);

pp Inform my manager of any personal orfamily ties I may have with a third party
in relation to my Company;

pp Inform my Compliance manager of any

potential direct or indirect conflicts ofinterest and abstain from participating
in discussions or decision-making on
the subjects concerned.

A MU N DI / CODE OF CON D U CT

29

17

EXAMPLES?
I receive a case containing
six bottles of champagne
at home, can I keep it andenjoy it with my family?
➞ You must declare any
gifts received at yourhome address to yourmanager. If the gift exceeds
the maximum amountauthorised per client andper year, you must apply for
it to be authorised by yourmanager who will notify theCompliance Department
before it is accepted or
declined.

?
I work in a country where
it is customary for large
foreign companies tomake contributions to themain political parties. Is it
possible to contribute on
behalf of Amundi?
➞ No. Even if thiscontribution is permitted
by local law and customs,
Amundi may be held
responsible. Informyour manager and theCompliance manager
immediately.

GIFTS ANDI N V I TAT I O N S

DEFINITION
Corporate gifts are those that are offeredwithin the context of business relationship.
Some may be worth a significant amount (trips,
electronic equipment, wine, champagne, etc.)
and are therefore monitored to avoid any riskof corruption.
Invitations include any form of social contact
and invitation either offered or received.
In a commercial context, these businessdevelopment interactions take the formof meals, hotel accommodation, seminars,
conventions or conferences, or invitations tosports, cultural and social events, according tolocal customs. Business and press travel canalso be added.

AMUNDI’S COMMITMENT
E m p l oye e s m u s t n o t a cce p t g i f t s o rinvitations, directly or indirectly, which may,even unintentionally, compromise their
independence, impartiality or integrity.
They must refuse all gifts or invitations that
could place them in a conflict of interests.

I MUSTNo gifts may be sent to the employee’s homeaddress, and they must only provide his
professional address for the delivery of gifts.
Amundi does not prohibit the offer or
acceptance of gifts or invitations in the context
of business development. Such transactions
must have a clear commercial justification andmust be subject to the prior authorization of
the line management if the maximum amountprovided for is exceeded. In the event of doubt,
the Compliance Department may be asked foran opinion.

I MUST NOT
pp Accept or give any gifts or benefits

pp Before accepting a gift or an invitation,

pp Solicit any form of gift or benefit forask myself how this could be perceived
publicly and refuse offers that might
create a conflict of interests for myself;

pp Be transparent with my manager toavoid any suspicion;

pp Refuse invitations to high-worth events;
pp If I accept an invitation, pay the

associated travel and accommodation
expenses;

pp Comply with the internal declaration

procedure.

A M U N D I / CO D E O F CO ND U CT

For gifts and benefits accepted or granted,
a maximum amount is set per business
relationship and per year. If the value of the giftor benefit exceeds the maximum authorizedamount (set according to local requirements),
the employee must, before being able to accept
or grant it, notify his manager and Compliancemanager, who will give their agreement if
appropriate.

pp If I am a manager, make sure that mystaff are aware of the rules regarding
gifts and invitations, businessdevelopment activities and businesstrips;

30

In the same way, it is forbidden to solicit gifts
from individuals or companies which either
have, or are trying to develop, business relations
with Amundi.

worth more than the authorized fixedamount or receive any of these at mypersonal address, regardless of theamount;myself or on behalf of a third party;

pp Receive any form of remuneration froma counterparty, intermediary, supplier orcustomer, either directly or indirectly;

pp Give or receive gifts in cash.

18

LO B BY I N GAND FINANCING
P O L I T I C A L PA R T I E S

EXAMPLES?
What should I do if one of ourcustomers asks me to support
his political campaign in thelocal elections?

DEFINITION

AMUNDI’S COMMITMENT

Lobbying or the representation of interests
describes any direct or indirect communication
with public officials for the purposes ofinfluencing public decisions. Consulting people
representing interests enables the legislator
to obtain information about how the law isenforced and how to improve it. It also gives
public decision-makers greater insight into
what civil society expects.

In cooperation with the relevant tradeassociations and the experts and practitionersof the various Amundi entities and/or the
Crédit Agricole Group, lobbying enables
Amundi to contribute positively to thedevelopment of or changes in the regulations
that apply to its activities. Its purpose isto provide a reasoned and professional
perspective with in order to improve legislativeand regulatory decisions pertaining to its
areas of activity. Amundi complies with thecommitments of Crédit Agricole Group’s
Responsible Lobbying Charter.

The financing of political parties by legal
entities (companies, foundations, etc.) is strictly
forbidden.

In addition to fully respecting the ban on
financing political parties, even in countries
where this practice is permitted, Amundi
complies with the commitments of the
Crédit Agricole Group by insisting that its
political convictions and commitments of its
employees remain personal so as never to
implicate or jeopardise the reputation of theGroup. These commitments must be madeoutside of working hours and outside theCompany.

I MUST
pp Be transparent about my lobbying

activities both inside and outside
Amundi;pp Declare the offices I hold in various

trade associations;pp Base my arguments on reliable➞ Refuse this request for
support in order to ensure thepolitical neutrality of Amundi
and immediately inform yourmanager or your Compliancemanager.

?
I work in a country where it
is customary for large foreigncompanies to finance the main
political parties. Can Amundi
make such a contribution?
➞ No. Even if this form ofmonetary support is acceptedby law and local customs,
it could expose Amundi toliability. Inform your manager
and the Compliance manager
immediately.

pp Declare my elected public offices to mymanager and Compliance manager;

pp Make sure that my political opinions

and actions do not commit Amundi toanything;

pp Refuse any request in any form

whatsoever that requests my politicalsupport and could make Amundi liable.

information that has been analysed andaudited at the internal level;

pp Highlight the consequences for thedifferent stakeholders;

pp Record all organisations on behalfof which I lobby in the register ofrepresentatives of interests, if one
exists;pp Update the list of appointments I
make with public decision-makers,
for the purposes of influencing publicdecisions, so that I can draft the annual
report of my activities, as required bylaw;

I MUST NOT
pp Use corrupt practices and any

dishonest or abusive practices;

pp Use Amundi’s resources or funds toengage it in fund-raising or politicalsupport activities;

pp Offer or accept any gifts and benefits.

A MU N DI / CODE OF CON D U CT

31

19

EXAMPLE?
A client contacts meabout the possibility ofAmundi participating in
the financing of a charity
association which he isfamiliar with. What should
I do in such a situation?
➞ You must contact
your manager and/or
your Communications
Department immediately
to assess this situation anddetermine the process tofollow.

PAT R O N AG E A N D
C H A R I TA B L E AC T I O N S

DEFINITION

AMUNDI’S COMMITMENT

Patronage is a financial or material form of aid
provided by a company or an individual to a
general interest initiative or activity (cultural,
research, humanitarian issues, etc.).

Since its inception, Amundi has always been acommitted operator; a feature impregnated inits DNA and reflected in its values.

It differs from sponsorship and providing
financial backing by the nature of theinitiatives supported and by the fact that
there are no contractual advertising or public
relations counter-parties involved in the
support provided by the patron. The patron’s
involvement in the event or initiative supported
is therefore relatively discreet but may bereferred to on its own communication media.
Patronage is often related to corporate
values, but may serve to enhance image andcommunication and/or internal motivational
purposes.
Patronage benefits from tax deductions, unlikesponsorship which is considered an advertising
investment.

I MUST
pp In the case of a new support project,

check that it corresponds to at least
one of our pillars;

pp Prioritise organisations or causes whose

accounts are published and regularly
consulted;

pp Ensure that all agreements enteredinto with the organisations in question
incorporate compliance clauses andmake sure you are in a position to verify
how these funds are used;

pp Ensure that all expenses incurred bycharitable organisations have been
properly authorised, accounted for anddocumented.

32

A M U N D I / CO D E O F CO ND U CT

Our corporate patronage policy draws on
the values of the Company and those of the
Crédit Agricole Group.
To give meaning to our action, our support isbased on three pillars in line with these values:
culture, education and solidarity. Any action
undertaken or new support provided must
therefore be in line with one or more of thesepillars.
Because our aim is to support our beneficiaries
over time, our support is for the most partsustainable, and only on exceptional occasionsof an individual nature.
All of our support actions are compliant with
the Crédit Agricole Group’s Ethical Code.

I MUST NOT
pp Make donations to individuals or for-profit organisations;pp Fund works whose purpose and actions

are unclear and cannot be verified;

pp Support organisations that could

have a negative impact on the
Company’s reputation, its image or the
Crédit Agricole Group’s;

pp Make cash payments.

20

SPONSORSHIP

EXAMPLE?

DEFINITION
Sponsorship refers to financial or material
support provided to an event or individual byan advertising partner in exchange for different
forms of advertising-related visibility related tothe event or individual.
In addition to the various forms of visibility foradvertising purposes, sponsorship contracts
may provide for a number of counter-parties
related to public relations or the participationof the sponsored individual in various company
events (conferences, seminars, opening ofpoints of sale, product launches, etc.).
The advertiser-sponsor seeks potential visibility
in relation to the event as well as positive imagetransfers depending on the type of event
being sponsored and the values associatedwith it. It can also use its sponsoring activities
at an internal level to motivate and engage
employees.

I MUST
pp Select organisations, institutions or

disciplines that are in line with Amundi’s
objectives and values;

pp Prefer organisations whose experienceand reputation are established, andwhose accounts are published andregularly consulted;

pp Draw up a contract including

compliance clauses with the sponsoredorganisation;

The most common and visible form ofsponsorship is related to sports. Sports
sponsorship differs from patronage in termsof form and tax treatment.

AMUNDI’S COMMITMENT
Sponsoring sports forms part of Amundi’s
communications.

An operation seems worthy of
being sponsored, who should I
contact?
➞ First of all, contact theCommunications Department.
Do not commit any funding that
could damage the reputation of
the Company. The allocation offunds must be transparent anddone in coordination with theCommunications Department.

Sponsorships must comply with the principles
and internal rules of the Crédit Agricole Groupand must never be used to unduly advantage,
improperly influence or give the appearance ofimproperly influencing any person in charge ofmaking decisions.

I MUST NOT
pp Sponsor an organisation suggested bya public official;

pp Sponsor an organisation that indirectly

benefits, or is controlled by, politicians,
public officials or their relatives;

pp Sponsor an organisation related toprojects in which Amundi and/or the
Crédit Agricole Group are involved forcommercial purposes.

pp Implement measures to verify

objectives in terms of visibility andpublic relations.

A MU N DI / CODE OF CON D U CT

33

Our rules of conduct
protecting Amundi
and its reputation
21. Confidentiality
35
22. Fight against the money laundering and financing of terrorism 36
23. The fight against tax evasion
37
24. International sanctions38
25. Prevention of fraud
39
26. Prevention of market abuse
40
27. Using social networks
41

34

A M U N D I / CO D E O F CO ND U CT

21

CO N F I D E N T I A L I T Y

EXAMPLES?

DEFINITION

AMUNDI’S COMMITMENT

Confidentiality and professional secrecy
are fundamental principles in the financial
profession and in asset management. They
must be an ongoing concern for all employees,
regardless of the area in which they performtheir duties.

Confidentiality must be respected in all
circumstances and applies to all types of
media. All employees are the custodians of andresponsible for the confidential information theyreceive. Employees may use this informationinternally for professional purposes and makedisclosures outside the Company only if
authorized to do so or in the cases provided
for by law.

DETAILS
All information relating to customers, aswell as to Amundi, the other entities of the
Crédit Agricole Group, their employees, theircustomers, and their internal organization,
information systems, security procedures,
suppliers and subcontractors, is confidential.
The disclosure of any confidential information
makes the establishment and the employee
involved liable.
When this concerns non-public information of alisted company, a breach of confidentiality may
be the subject of a criminal, administrative or
professional sanction.

I MUST

Within the entity itself, a system known asan “information barrier” is put in place toprevent conflicts of interest and to avoid theundue circulation or improper use of sensitive
information, in particular information that
could be classified as confidential or privileged
information.
Employees must also apply the principle ofconfidentiality with the utmost rigour when
they are outside the entity. This concerns theuse of social media but also conversationsin the private (family, friends, etc.) or publicsphere (public transport, restaurants, public
places in general). They are responsible for theirInternet publications and must ensure that they
do not disseminate information on the Internetthat they would not otherwise provide outside
the entity. This principle of confidentiality also
applies to professional social networks.

I MUST NOT

pp Respect the strict confidentiality of

pp Disclose any information aboutpp Always obtain the express written

pp Send any confidential information in

the information to which I have accessconcerning Amundi’s customers andmore generally belonging to the
Crédit Agricole Group;
authorisation of customers when I
need to transmit a piece of confidential
information that concerns them, except
in cases expressly provided for by local
provisions;pp Only share confidential information

within Amundi or the Crédit Agricole
Group, with the persons concerned andsolely for the purposes of their duties;

Amundi’s customers or about Amundi
or the Crédit Agricole Group to outside
persons, except in cases expressly
provided for by local provisions;

I am travelling on public
transport and want to takeadvantage of the journey toget ahead in my work, can I
do it?
➞ The screen of a laptop
computer, without a privacy
filter, is easily readable by otherpassengers. Do not work on
confidential documents underthese conditions. The same
applies to tablets and mobile
phones.

?
I have to write the minutes of
the Strategic Committee anda colleague offers to help mewith the layout. Can I forward
it to him by e-mail?
➞ You must guarantee theconfidentiality of this document
and limit its circulation. If yourcolleague did not attend themeeting, you cannot give him or
her this task.

?
I am on public transportand I receive a call frommy customer who wants
clarification on a current caseand his questions require
answers with elements ofconfidentiality.
➞ In this case you should explainthat you are in a public place andthat you contact him as soon as
you are in private.

personal emails;

pp Disseminate on the social or othermedia, any information that could harmcustomers, my entity, my function orAmundi;pp In public places and in moments ofprivate life, I cannot mention sensitive
information or confidential information
relating to business transaction.

pp Always make sure that a confidentiality

agreement exists before sharing
confidential information with an
external business contact;

pp Protect confidential information against

unauthorised use and access;pp If I have any doubts about the

information I want to diffuse on thesocial media, ask my manager orCompliance manager beforehand.

A MU N DI / CODE OF CON D U CT

35

EXAMPLES?

22

Is my client’s identification
enough to enter into abusiness relationship?
➞ No, each Amundi entity
must formally identify thebeneficial owner(s) of its
customers by appropriate
means and verify theidentification elements
by means of appropriate
supporting documents atthe time of entering into
the relationship, and inany event before initiating
any transaction with thecustomer. Entities must beable to demonstrate theirdue diligence and keep
supporting documents.
➞ If it is impossible toidentify the beneficial ownerwith respect to a business
relationship, the continuationof the relationship must
be questioned and thetermination considered anddocumented.

F I G H T AG A I N S T T H E
MONEY LAUNDERINGAND FINANCINGOF TERRORISM

DEFINITION
Money laundering and the financing of terrorism
are phenomena of unprecedented scale. They
affect society in general and the economic
development of countries. This enables
criminals to infiltrate financial institutions,control certain economic sectors, corrupt
management organisations and governments,
affect citizens’ lives, and undermine key
principles such as democracy.

Terrorism may also be financed by legal funds,
that are used to carry out a terrorist attack. Thisis referred to as “reverse money laundering”.

AMUNDI’S COMMITMENT
Amundi participates in the fight against money
laundering and the financing of terrorism.

DETAILS

Any breach of our obligations exposes directors,
managers, and employees to civil, criminal,
administrative and disciplinary sanctions. In
addition, Amundi’s image and reputation are
at stake.

Money laundering is the process of making
money, obtained by illicit or criminal means,
appear clean. The laundering of illegal funds
is also used for the purposes of financing
terrorism.

Money laundering and terrorist financing areoften based on complex financial arrangements,
the identification of which requires a highdegree of vigilance and good coordination
between the actors holding the information.

I MUST

pp Refuse to carry out any transactions that?
I note that a client could
have activities in sectors
or geographical areas
considered risky, what
additional due diligencemeasures should I apply?
➞ Whenever it is identified
that a client or its beneficial
owner may have an activity
in a sector consideredrisky or in a country undersurveillance, enhanced due
diligence designed to provide
additional informationon the client/beneficial
owner (details of activities,
countries, shareholders,
negative information, etc.)
must be carried out andagreement on its complianceobtained for the informationcollected.

pp Make sure I am kept informed about

these topics even if I am not directly
exposed;pp If I am a manager, do my utmost toensure that my employees are wellinformed about these topics;

the Financial Security Department of theCompliance Department.

laundering and anti-terrorist financing
procedures;

pp Pay particular attention to being awareof my clients when entering into a
relationship and throughout the entire
process;

for any unusual, atypical, complex
transactions that have no apparent
economic justification and could clearlybe illegal;

pp Ask customers to provide a reasoned

explanation for their transactions;A M U N D I / CO D E O F CO ND U CT

pp Report any suspicious transactions to

pp Actively implement anti-money

pp Remain vigilant at all times and look36

are not economically justified or where
there is any doubt as to the identitiesof the originators or the beneficiaries(knowledge of beneficial owners);

I MUST NOT
pp Fail to apply procedures strictly. For

example, for commercial reasons;pp Tell customers that they may besuspected of money laundering, or
reveal such information to a third party;

pp Perpetrate, advise or assist in

any placement, concealment or
consolidation transaction.

23

F I G H T AG A I N S T
TA X E VA S I O N

EXAMPLE?
I have dual citizenship andlive outside the United States.
I don’t think I should beconsidered a US citizen.

DEFINITION
Tax evasion is the act of consistently avoiding
to pay or reducing tax in an illegal manner. Tax
evasion concerns both companies andindividuals.

for the purposes of identifying the assets
held by tax residents living outside theirhome jurisdiction. This is the systematic andperiodic disclosure of information on theincome of taxpayers (individuals and entities)
by the country of the source of income totheir country of residence.

This can take various forms (in particular, failure
to declare or declaring lower levels of income
and/or results) and involved sophisticatedfinancial engineering (notably cross-border).

AMUNDI’S COMMITMENTDETAILS

Amundi considers that a consistent andresponsible tax approach is an essential partof the long-term strategy.

FACTA (Foreign Account Tax ComplianceAct) and AEOI (Automatic Exchange ofInformation) regulations, two tax measureswith which Amundi must comply, give different
tax administrations access to information andenable the fight against tax evasion and tax
fraud.

Amundi treats all tax issues with integrity
and transparency. All operations andtransactions carried out have a sound economic
basis and Amundi does not seek to avoid tax
through structures provided for this purpose.

2. AEOI was an initiative of the OECD to carryout multilateral exchanges of information

Amundi undertakes not to set up or propose
operations exclusively for tax purposes, or toassist its customers in circumventing their tax
obligations or operating in states or territories
whose jurisdictions are categorised by the EU
as “non-cooperative” (tax havens) or which do
not take part in the Automatic Exchange ofInformation.

I MUST

I MUST NOT

1. FATCA was introduced to collect informationon the assets and income held by US
taxpayers (“US persons”) living outside theUnited States;

pp Respect, in a totally transparent way,

the laws and regulations in force in thestates and countries where we carryout our activities;

pp Request permission from the Tax

Department and the ComplianceDepartment before any investment by
an entity in a non-cooperative foreignstate or country;

pp Remain alert, identify any action aimed

directly or indirectly at circumventing
tax rules and report this immediately to
the Compliance manager;➞ Because you have dual
citizenship you are considered a“US Person” with the obligations
attached thereto. Unlike mostother jurisdictions, liability
to US taxation is attached
to citizenship not place ofresidence. This means that US
citizens living abroad must file anannual US tax return, regardlessof their place of residence.

pp Deliberately shield Amundi from its tax

obligations;pp Advise a client and/or participate ina financial engineering arrangement
aimed at circumventing tax rules;

pp Sign any self-certifications on behalf ofa customer;

pp Remove or conceal any information

for the purposes of covering up any
evidence of an operation being linked
to a tax haven.

pp Compile a customer knowledge filefor all your clientele that includes
information on their tax residence(AEOI) and citizenship criteria (FATCA)
and ensure it is kept up to date;

pp If in doubt, contact your Compliancemanager.

A MU N DI / CODE OF CON D U CT

37

24

EXAMPLES?
I hold dual FrenchAmerican nationality
and I am an employee ofAmundi. Which regulations
should I refer to?
➞ You are then referred toas a “US Person” affiliated toAmundi. As such, regardlessof your location, you must
inform the Human Resources
Department of your status
and read the technical note
describing the obligations to
be respected in accordancewith the legal provisions of
the Office of Foreign Assets
Control (OFAC).

?

I N T E R N AT I O N A L
SANCTIONSDEFINITION

AMUNDI’S COMMITMENT

International sanctions are measures taken
by one or more states against natural and/or
legal persons (for example freezing assets) andagainst countries or governments (embargomeasures). Sanctions are taken to combat
terrorism, nuclear proliferation activities andhuman rights violations.

Amundi strives to ensure strict compliancewith the law on international sanctions, which
can be complex and of extraterritorial scope incountries and territories where the Company
carries out its activities. Compliance withthese requirements is ensured through thestrengthening of internal procedures and of
programs ensuring compliance with the law
on international sanctions. These are applicable
to all Amundi’s employees, regardless of thecountry and the size of their entity. Amundi
does not tolerate any breach of internationalsanctions.

DETAILS
Most of the international sanctions applicableat the level of Amundi are issued, administeredor enforced by the UN Security Council, theEuropean Union, as well as by competent local
authorities.

A new client wants toinvest in UCITS units andhis company is located in
Honduras. Can I finalize thetransaction?
➞ Caution: before seeking
to acquire new Direct
Clients in countries classified
within group 4 in Amundi’s
Country Risk Policy, priorauthorisation is required
from the ComplianceManager of the relevant
entity. You must always,
therefore, consult theCountry Risk Policy andpresent your proposal toyour Compliance contact
for approval in order toproceed with approaches tocommercial prospects.

I MUST
pp Become well acquainted with,

understand and comply with Amundi’s
internal policies and procedures;

pp Complete the annual training sessions

which are mandatory for all employees,
as well as additional training courses
eligible for certain people;

pp Remain attentive to, identify andpromptly report to the Sanctions
Manager of the ComplianceDepartment any violation or attemptedviolation of international sanctions, aswell as any action taken, directly or
indirectly, to circumvent them;pp Keep your customer knowledge files up

to date and complete;

pp Monitor the compliance of operations

with international sanctions;pp If in doubt, contact my manager andCompliance manager.

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A M U N D I / CO D E O F CO ND U CT

I MUST NOT
pp Participate in any financial transactions

that do not justify their complexity;

pp Remove or conceal any information forthe purposes of covering up evidenceof a transaction with countries or
persons that are subject to internationalsanctions;

pp Modify tools or IT processes for the

purposes of removing informationthat is useful for detecting the risk ofinternational sanctions;pp Advise a customer and/or participate

in a financial arrangement aimed atcircumventing international sanctions.

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PREVENTIONO F F R AU D

DEFINITION

EXAMPLES?

pp Internal fraud: a malicious act carried out

Fraud is an intentional act that is carried out
for the purposes of obtaining a material orintangible benefit, to the detriment of a third
person or organization.
Where laws, regulations or internal rules arebroken, fraud is characterized by the violationof the rights of others and the total or partial
concealment of an operation, a set of operationsor their characteristics.

by an employee to the detriment of theircompany or of interests of any third parties
managed by the Company.
pp Fraud can also be characterized by amalicious act carried out by an employeewith the complicity of individuals outside
the Company. This is referred to as mixed
fraud.

AMUNDI’S COMMITMENTDETAILS
Two types of fraud exist depending on theorigin of the malicious parties involved:
pp External fraud: an act carried out by

Amundi places great importance on theprevention of fraud, which uses a growing
number of techniques that are increasingly
more sophisticated, particularly in the light ofthe digital transformation.

individuals (customers or otherwise), on
their own or in a group for the purposes ofobtaining funds, documents or information
they can use for their own benefit and to
the detriment of a company, its customers
or third parties;

To combat the surge in the number of casesof fraud, it is essential to tackle the issue atboth the upstream and downstream levels.
All employees, whatever their duties, have arole to play in preventing fraud. With the daily
vigilance of everyone in the Company we canprevent and detect attempts at fraud.

I MUST

I MUST NOT

pp Be well acquainted with the law

pp Take advantage of information

pp If I suspect anything fraudulent or are in

pp Transmit information to a third party

and best practices concerning fraud
prevention, and apply them responsiblywith constant vigilance;
doubt, immediately alert my manager
and the Compliance Prevention unit of
the Compliance Department so thatthey can act quickly;

pp If in doubt about the purpose of anemail asking me to perform an unusual
financial transaction, forward it to mymanager and notify the ComplianceDepartment;

pp If I am a manager, evaluate the risk of

fraud attached to my activities, andenforce the principles of good conduct
as well as the general professional rules;

pp Perform fraud-risk analysis at thestart of the design process for all new
products and activities.

I have just received an email
from an unknown address
asking me to carry out atransaction on behalf of adirector of my entity, whatshould I do?
➞ Since this situation is abnormal
and could constitute “fraud
against the President”, youmust inform your manager,
and forward the email to the IT
Department for identificationof the sender. Notify theCompliance Department also.

?
A client simultaneously
requests a change in his or
her bank statement and theredemption of all units in his
or her portfolio, what should
I do?
➞ Increased vigilance must be
applied to this type of request.
Contact the customer to confirm
that the requests are from him/
her, and process these requests
according to the security
measures that apply in this case.

that would allow me to carry out afraudulent act to my advantage or tothat of a third party;
that would allow him to carry out afraudulent act;

pp Reply to an email from an unknown

sender asking me to carry out an
unusual transaction or to bring to
his attention information relating toAmundi’s business;

pp Communicate my passwords toanyone, lend my access badge, or leave
confidential information or documentson my desk;

pp Leave confidential information or

documents on my desk or where
they can be seen by other employees(meeting rooms, photocopiers, etc.);

pp Discuss sensitive issues that could

involve Amundi in public;

pp Use external media (external hard

drives or USB sticks) without taking
precautions, or use unsecured external
media.

A MU N DI / CODE OF CON D U CT

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EXAMPLES?
During my morning coffee
break, I understand froma conversation that alisted company is planningto buy another listedcompany. This informationthat has not yet been
made public. Can I makea financial transaction on
the securities of thesecompanies?
➞ No. The legislation
governing financial
markets is based on equal
information for investors.
In other words, until theinformation concerned
has been made public,
no transactions can be
authorised.

?
A friend asks me toadvise him/her on the
management of his/her
investments as part ofhis/her PEA. Can I advise
him/her to buy or sell the
security that for which I
am an insider?

PREVENTION
OF MARKET ABUSE

DEFINITION
Insider trading, share price manipulation and thedissemination of false or misleading information
are all examples of market abuse. The fightagainst market abuse means preserving the
integrity and transparency of markets as wellas public trust. As such, it is the responsibilityof everyone to respect the principle of equalityof information between investors.
In the event of a breach of these rules, theinvestment services provider and the natural
persons placed under its authority may besubject to disciplinary, financial, civil andcriminal penalties.

DETAILS
If confidential information relating to alisted company is made public, this “insider”
information may influence the market price ofspecific financial instruments or those related
to them. Confidential information can also be
communicated in writing or by verbally, or
simply deduced.

➞ No, as an insider on thissecurity you are bound by
an obligation to abstain.
You are strictly prohibitedfrom communicating,
distributing or using any
insider information in mypossession, whether on yourown behalf or on behalf of athird party.

I MUST
pp Be attentive and take all necessary

measures to avoid disclosing any
insider information. This means
respecting the information barriers inplace;

pp If I am on an insider list, abide by the

associated abstention obligations;pp If I think I am in possession of insider

information, I must tell my manager
who will inform the Compliancemanager;pp Immediately report any transaction

where there is a suspicion of market
abuse to the Compliance Department,
which, after analysis, will decide
whether or not it is appropriate toreport the transaction to the competent
financial markets authority;

pp Preserve the confidential nature of any

suspicious transaction declarations and,as such, not communicate with thosesuspected of having committed market
abuse, proven or otherwise.

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A M U N D I / CO D E O F CO ND U CT

Using, transmitting and recommending thisinformation for one’s own account or for that ofa third party constitute acts of insider dealing
and, as such, are strictly prohibited and subject
to severe penalties.

AMUNDI’S COMMITMENT
Amundi has implemented a system of
information barriers to protect insider
information. These provisions mean thatpeople who are privy to insider informationmust comply with the insider information
management mechanism set up within theirentity.
The barriers also ensure the strict control
of communications between people who,
because of their function, have access to insider
information, and those who do not. In particular,
this involves the physical separation of people
carrying out sensitive activities or functions
from those who do not.

I MUST NOT
pp Use insider information when acquiring

or transferring instruments, contracts,or financial or stock market securities towhich this information relates, whether
for my own account, or on behalf ofAmundi or of a third party;

pp Communicate insider information to athird party outside the normal scope of
my duties, to persons outside Amundi
or to employees who are not authorized
to access such information;

pp Manipulating prices by manoeuvres

designed to interfere with the freeestablishment of the price, misleading
the public, or intended to secure adominant position on the market;

pp Recommend taking positions on asecurity based on insider information to
any third party (employee of Amundi oranother Crédit Agricole Group entity, oran external third party, etc.).

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USING SOCIALN E T WO R K S

EXAMPLES?

DEFINITION

AMUNDI’S COMMITMENT

The term “social networks” generally refers to
all websites that can be used to build a networkof personal or professional contacts and to
exchange opinions or information.

Amundi is present on many of these social
media networks (Twitter, Facebook, LinkedIn,etc.) so that it can communicate with its
customers stakeholders, while taking note ofany comments made.

DETAILS
Social media (social networks, blogs, forumsetc.) are now part of our everyday life andconcern all Amundi employees at both thepersonal and professional levels. However, they
do present risks. Given the number of different
media platforms and the volume of informationexchanged on them, mastering this form ofcommunication has become a real challenge.

Except where abuse is involved, all Amundi
employees enjoy freedom of expression both
inside and outside the Company. Nevertheless,everyone must act responsibly by behaving
in an appropriate manner and adopting
best practices. Employees may use thesocial networks for private purposes at theirworkstation provided they do not abuse thisprivilege but use it properly, on an ad hoc
basis, and without over-stepping their rightto freedom of expression to the detrimentof the Company, its directors and workplacecolleagues.

I took some pictures at the
farewell drinks party of oneof my colleagues, and would
like to publish them on mypersonal page as a souvenir.
➞ To respect the right to theprotection of one’s image, ask
prior authorisation from thepeople concerned. For any
publication, you must assess
whether there is a risk that it
could harm your reputation orthat of any other natural or legal
persons.

?
As part of a new project, acolleague suggested I create agroup on LinkedIn so that we
could exchange information
between ourselves and share
documents.
➞ Refuse: Amundi does not
permit its employees to exercise
their business activity on thesocial networks, unless in very
exceptional cases. Discuss the
project with the Communications
Department.

?
I MUST
pp Respect the rules of confidentiality

and secrecy to which I am bound byprofessional obligation;

pp Be aware of the general conditions ofuse about how your personal data andthe information you put online may be
used;

pp Pay particular attention to social media

networks whose servers are hosted
in a foreign country, which may havedifferent personal data protection rules
than those in France;

I MUST NOT
pp Carry out my business activity on thesocial media without having obtained
authorisation from the Communications
Department;

pp Express myself officially on behalf ofAmundi if you are not a spokesperson
appointed by the Communications
Department;

pp Make any remarks that could harm yourposition or Amundi and its employees;

to ensure the confidentiality of yourprofile and comments;

pp Specify that your remarks are yourpp Enter into any form of communication

sole responsibility and express yourpersonal opinion;

pp Do not intervene directly if you readany negative or slanderous comments
about Amundi and Crédit Agricole
Group to avoid giving the authors
more visibility. When you come across
such comments, forward them to theCommunications Department;➞ You can present your duties
and the activity of the Company
in general. But do not share
any confidential information or
mention any of your “sensitive”
duties.

pp Make comments such as malicious

criticism or insults, or remarks of adisparaging, defamatory or indiscreet
nature or divulge any confidential
information;

pp Check your settings functionalities

I want to create or update my
LinkedIn account, and publish
information about my activity
with Amundi.

that supports a political, societal or
religious commitment, by associating
your professional activity within
Amundi;pp Use information that is protected by

Amundi copyright without having
obtained prior written consent fromthe relevant department or, failing that,from the Communications Department.

pp If in doubt about the nature of theinformation, do nothing and ask yourmanager.

A MU N DI / CODE OF CON D U CT

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A M U N D I / CO D E O F CO ND U CT

AmundiA French limited company with share capital of €504,260,885
Credit institution governed by the French Monetary and Financial CodeRegistered office: 91-93, boulevard Pasteur 75015 Paris, France
Postal address: 90, boulevard Pasteur, CS21564, 75730 Paris cedex 15, France
Telephone number: +33 (0)1 76 33 30 30
SIREN number: 314 222 902 RCS Paris
LEI : 9695 00 10FL2T1TJKR5 31
Websitewww.amundi.com© Photo credit: iStock

Printing: Handiprint “entreprise adaptée”, an adapted structure employing people with disabilities, in July 2019, on paper from sustainability
managed forests.