HUMAN RIGHTS Due diligence CNP Assurances has always upheld human rights and citizens rights, in line with the Universal Declaration of Human Rights, and has always complied with international labour standards as defined by the ILO, and the national labour laws in each of its host countries. All employees are covered by insurance industry collective bargaining agreements, except for 15 managers in Argentina, who are not eligible under local legislation. Employees in China are protected by the labour law that came into force on 1 January 2008. In pledging its support for the Global Compact in 2003, CNP Assurances reaffirmed its commitment to respecting its fundamental principles, combating corruption and protecting the environment. In 2010, following the example of CNP Argentina and Caixa Seguros, CNP UniCredit Vita also pledged support for the Global Compact. The same due diligence is exercised in asset management. Environmental, social and governance criteria are now applied to 55% of managed portfolios. In 2009, CNP Assurances played an active role in launching the Association Française de l Assurance s sustainable development charter. Its commitments under the charter are to meet core social responsibility challenges in the insurance industry, including helping to reduce social vulnerability and to combat climate change, support economic development and promote socially responsible investment. Updated in 2010, the Code of Conduct serves as the Company s internal rules. It is posted on the intranet site and printed in the Employee Orientation Guide for new hires. Certain units, such as Purchasing and Internal Audit, have their own ethical codes. Purchasing policy: an employee protection clause is included in all calls for bids, requiring suppliers and their subcontractors to pledge to respect human rights and to comply fully with French labour laws. Candidates that do not fulfil these criteria are excluded from the competitive bidding process. Training: in 2009, buyers received training using modules developed by Caisse des Dépôts. Employees received sustainable development awareness training over the intranet and quizzes organised as part of Sustainable Development Week focused on all related topics, including human rights. Indicators: 0.2% of employees received specific training (buyers) 100% received awareness training. 1
Human rights risk situations Equal opportunities To live up to its Seal of Diversity obtained in January 2009, CNP Assurances constantly strives to reduce any pay gap observed between men and women, in line with the applicable regulations. An in-house diversity steering committee was set up in 2010. Meeting twice a year, the committee reviews the actions undertaken in each business to ensure consistency throughout the organisation and facilitate the global management of the Group s diversity policy. Following an audit in September 2010, AFNOR, the French national organisation for standardisation, renewed CNP Assurances Seal of Diversity. Investment Equities are screened for compliance with human rights. Criteria for investing in government bonds include an absence of any corruption as well as basic freedom and democracy. Before the Company actually makes an investment in a given fund, questionnaires are sent out to fund managers (SRI funds, private equity and infrastructure funds) that cover pledges to support the Global Compact and Principles for Responsible Investment. Avoidance of complicity Subcontractors are all located in France. An employee protection clause is included in all calls for bids requiring suppliers and their subcontractors to pledge to respect human rights and to comply fully with French labour laws. Candidates that do not fulfil these criteria are excluded from the competitive bidding process. Since 2008, Caixa Seguros has included in its supplier contracts clauses that cover the Global Compact principles relating to international labour standards, combating organised crime and drug trafficking, the environment, fraud and money laundering. These clauses are also added to contracts signed before 2008. The other subsidiaries are also making progress in this area in terms of both products and subcontractors. (Awareness-raising up sessions are organised within the CNP UniCredit Vita has set up a Green Group and SFLI in China is focusing on responsible purchasing.) Environmental and social criteria are also applied when choosing suppliers. Compliance with these principles is verified. After an audit of 50 suppliers in 2008, a survey was conducted among more than 40% of IT subcontractors in 2009/2010, representing 31% of the purchasing spend in 2010. Discrimination and vulnerable groups Diversity CNP Assurances regards diversity as a source of strength as well as a formidable vector for social, personal and economic success. This has been one of the lynchpins of its HR strategy since 1995 when it made a commitment to promote disabled employment. 2
In 2006, CNP signed up to the Diversity Charter which enshrines its commitment to combating discrimination in all its forms throughout the Company. In January 2009, CNP was one of the first seven French companies to obtain the Seal of Diversity sponsored by the government, the trade unions and ANDRH (French Association of HR Directors). This provides recognition for the work already carried out and represents a commitment to go even further, under the supervision of AFNOR. Disabled employees accounted for 5.38% of the workforce in 2010, a testimony to the strides made in this area over the past few years. The Company has set itself various targets for the 2010-2011 period, notably the deployment of (i) more effective processes for enforcing anti-discrimination rules at all stages of human resource management (hiring, training, career advancement or promotion) and (ii) a global diversity management strategy that goes beyond just HR. An in-house diversity steering committee met for the first time in May 2010. It includes a number of senior executives and its twice-yearly meetings will be used to rally all of the Company s different functions around the policy. A number of measures have been taken to enhance HR processes, including bringing interview procedures into line with antidiscrimination guidelines and preparing a diversity handbook that analyses the HR areas impacted by diversity and individual roles and responsibilities. Gender balance The percentage of women in management-grade positions was stable at 50.5%, and the percentage of female senior managers remained stable at 25%. On average, the men/female salary per management level was down to 104,8% in 2010 (106% in 2006). An agreement to promote disabled employment has been in place since 1995. CNP Assurances employs 99 disabled people under permanent contracts and uses the services of sheltered workshops for the equivalent of 40 employees. It also houses a sheltered workshop in its offices. Disabled employees Corrective measures were taken in 2010, following a disability access audit at the Paris and Arcueil offices. Disabled employees accounted for 5.38% of the workforce in 2010, up from 4.62% the year before. Over 50s A 50+ action plan was launched in 2009 to strengthen the Group s commitment in six areas targeted by the law for the period 2009-2012. The number of people over 50 employed under fixed-term contracts was 25 in 2010 versus 6 in 2009. Outside France: In Brazil, Caixa Seguros Code of Conduct prohibits discrimination in any form. In Spain, the 2008 insurance industry collective bargaining agreement reinforces gender equality. 3
Economic, social and cultural rights Helping to fight financial exclusion Offering affordable products for customers in all income brackets - In October 2010, CNP launched the first interactive video website dedicated entirely to life insurance (www.toutsavoirsurlassurancevie.fr). Responding to a genuine quest for information, the site enables Internet users to learn more about insurance through an educational web series and information sheets. The site received more than 226,000 visitors in three months. - Together with its distribution partners, CNP offers very low minimum payments, despite the higher administrative costs: 30 for life insurance, 45 for employee savings plans, from 4.10 per month for personal risk insurance, which guarantees a death benefit of 25,000, and 23 per month for long-term care insurance, which guarantees a monthly payment of 500. - The leader in the group life insurance segment, the contracts for companies, non-profit organisations, local governments and hospitals enable all employees to enjoy the same insurance cover at the same price thanks to the effects of pooling. - The mortgages guaranteed by CNP Caution offer older customers an alternative to term creditor insurance products. - CNP Assurances has introduced new disability cover for policyholders presenting a serious medical condition that is available not only for private sector employees (as provided for in the Aeras convention) but also for public sector employees and non-salaried workers. - Microinsurance: CNP Assurances is a founding member of the Entrepreneurs de la Cité foundation, which aims to help entrepreneurs obtain insurance for their businesses, and is one of the partner insurers on the foundation s Insurance Kit, which offers death/disability and health cover. Around 400 new contracts were approved in 2010. - In 2010, CNP Assurances became the insurer for loans granted by Cil Procilia (partner to the French government s Action Logement housing loan scheme), thereby strengthening its ties with the social economy segment. At 31 December 2010, CNP Assurances provided term creditor insurance for over 16% of the Action Logement partnerships. Tailored risk selection procedure The term creditor insurance rejection rate remained below 0.2% in 2010. CNP Assurances works determinedly to help ensure that individuals presenting a serious medical condition have access to credit and insurance in line with the provisions of the Aeras Convention, going beyond the regulatory requirements. A total of 15,000 customers benefited from special measures taken since 2008 to remove barriers to insurance for customers whose health is not stable. Term creditor insurance premiums for low-income borrowers have been capped. 4
Fundamental principles and rights at work Basic rights are upheld through responsible investment practices and employee protection clauses included in purchasing processes as described previously. Dealing with psycho-social risks in the workplace Since June 2010, Company employees have been able to use a round-the-clock counselling and stress management service run by a subsidiary, Filassistance International. They may use the hotline to deal with stressful home or work situations that jeopardise their personal and professional stability. Filassistance will put them in touch with a medical and social services platform where they have access to clinical psychologists, doctors and social workers. This service complements the in-house mediation service set up in 2008 to prevent conflict and suffering at work as well as bullying and discrimination. The Filassistance platform may recommend that employees contact the Health and Safety department for their site or refer them to a mediator. Rights of disabled employees In 2010, CNP Assurance donated 100,000 to Hanploi, a non-profit organisation for disabled employment which the Company has supported since its creation. Civil and political rights Employees: The number of consultative meetings organised throughout CNP Assurances exceeds the legal minimum by more than 50%. Existing agreements in force throughout the Company cover key issues such as work and personal life-balance with different working time arrangements made available to employees (68.6% of the CNP Assurances workforce follow tailored work hours) and safeguarding employee health and well-being through an in-house social mediation service. Numerous agreements are negotiated with employee representatives on an annual basis including discretionary and statutory profit-sharing agreements and mandatory annual salary negotiations. Agreements signed in 2010 covered trade union resources, employee representatives terms of office, a pre-election agreement relating to employee representatives and works council members, and discretionary profit-sharing bonuses for 2010-2012. A new agreement on the integration of disabled employees covering 2011-2014, was signed in December 2010. An internal employee satisfaction survey was conducted in spring 2009 as part of the CDC Group s HR initiatives. An additional survey was carried out in autumn 2010, focusing more specifically on diversity in the workplace. 5
Policyholders: Complaints Taux de réclamation / nombre de contrats 0,09% 0,08% 0,07% 0,06% 0,05% 0,04% 0,03% 0,02% 0,01% 0,00% Secteur vie individuelle Secteur emprunteur 2007 2008 2009 2010 Individual insurance sector term-creditor sector The complaint rate has always been marginal. In 2010, it stabilised in the term creditor insurance segment and remained low in the individual insurance segment. Litigation In all, 1,439 lawsuits were in progress at 31 December 2010, a decline of 11% on the yearearlier figure. Fifty-nine percent of cases are won by CNP in the first instance, 71% on appeal and 74% when the matter is submitted to the Cour de Cassation (final jurisdiction resort of the French civil circuit). The mediation service was asked to examine 971 disputes in 2010 and 53% of them were resolved in the policyholder s favour. For information: Percentage of security staff who have received training in the Company s human rights procedures/processes as they relate to their activity Percentage of major subcontractors and suppliers who have been subjected to human rights compliance tests; measures taken Total number of incidents in which the rights of indigenous populations have been infringed Number of incidents by type no security staff CNP s partners have not been known to infringe human rights, nor to forcibly relocate staff. 0 0 6
Specific case of the Chinese subsidiary The Chinese subsidiary, SFLI, is 50%-owned by CNP Assurances. The General Manager is an expatriate employee of CNP Assurances which also appoints three out of the six members of the Board. It has a workforce of 61 and reports to the Company on all employeerelated and environmental matters on an annual basis. It complies with local regulations and has an employee representative body headed up by a female employee which helps employees as and when necessary. The General Manager regularly meets with the employee representative to outline the company s main strategic objectives and discuss requests from employees. As required by law, the employee representative body has been provided with the company s budget and business plan for 2011 which was previously discussed and ratified by the Board of Directors. The company ensures that no discrimination is practiced based on gender, age, political affiliation or religious beliefs. The subsidiary does not employ child labour, complies with local regulations and labour law and has never received complaints of harassment. Specific case of the Brazilian entity which is the largest subsidiary in the Group, employing half of all employees outside France: The Brazilian subsidiary, Caixa Seguros, is 51.74%-owned by CNP Assurances. The General Manager is an expatriate employee of CNP Assurances and six out of ten Board Members are appointed by the company. Caixa Seguros has a workforce of 745 and reports to the Company on all employee-related and environmental matters on an annual basis. It is especially committed to sustainable development and contributed directly to the Human Rights section of this report. It has declared that it complies with all criteria relating to human rights and refuses to work with any supplier that uses either forced or child labour. 7