A strict and selective policy
In 2010, Societe Generale decided to close, and to take to all the necessary administrative steps to close, all Group entities in those countries that are classed as non-cooperative countries and territories under French law (Ministerial Decree of February 12, 2010 updated by the Decree of April 14, 2011 and Decree of April 4, 2012 published in the Official Journal of April 12, 2012). On December 31, 2011, Societe Generale now longer owned, either directly or indirectly, any entities in the countries and territories concerned, with the exception of an investment banking subsidiary (SG Manila) and a private banking representative office (SG FSC Manila) in the Philippines, their official closure having been suspended by decision of the Philippine authorities. The Group also chose not to use its business licence in Brunei. In fact, as early as 2003, the Group implemented a series of rules governing those of its entities and companies located in tax havens, including the banning of any Group entities in those countries classed as non-cooperative tax havens by the OECD (6 countries) and named on the black list of the FATF (9 countries), excluding Monaco and Egypt. In the 29 other countries considered at the time to be tax havens by the OECD, the Group branch managers were required to be particularly vigilant. In doing so, the Group is fully compliant with the recommendations of the G20 which has yet to determine the appropriate sanctions. Moreover, given the likelihood of additional regulations in the future, the Group is awaiting the OECD's new lists as well as the recommendations of the G20 and other states before fine-tuning its policy. Tax havens have been a core consideration in Group policy for several years now. Societe Generale does not, however, rule out working in countries where it already has an established financial and banking business activity that meets the economic needs of a local or international customer base. All steps are taken to ensure that activities fully comply with tax law and Group regulations governing the fight against money laundering, corruption and the financing of terrorist activities.
Group compliance rules apply worldwide, particularly in those countries where legislation is not as strict. Finally, in accordance with Article L 511- 45 of France's Monetary and Financial Code, the notes to the Group's financial statements for 2011 include a list of all of its entities located in NCCTs. (page 410 of the registration document).