BIC - 2018 Registration document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Our societal responsibility [NFPS]

SA 8000 CERTIFICATION FOR THE BIC AMAZONIA FACTORY

In 2010, the BIC Amazonia factory obtained SA 8000 social benchmarking certification on a voluntary basis. In 2013 and in 2016, this certification was renewed for a further three-year period. Examples of results achieved include: improvement in relations between management and employees; greater transparency in the HR process, in relation to internal recruitment, training and skills development; and the rollout of best practices to subcontractors working directly at BIC sites.

Progress made in 2018 and performances ❯ In 2018, 25 contract manufacturers (for Consumer Products or BIC Graphic) were audited, representing 33% of our active contract manufacturers at year end. The audits directly requested and managed by BIC, revealed 1 zero tolerance, 18 major, 133 moderate and 145 minor deficiencies, and 28 corrective action plans were implemented. The four biggest areas of deficiency were found in management systems, health & safety and wages & hours: The facility has comprehensive working hour and wages ● management processes and procedures in a written manual that support adherence to social compliance requirements but they are not all being properly implemented : 6%.

The facility has comprehensive employee safety processes ● and procedures in a written manual that support adherence to social compliance requirements but they are not all being properly implemented : 5%. The facility has comprehensive emergency preparedness ● processes and procedures in a written manual that support adherence to social compliance requirements but they are not all being properly implemented : 5%. Total overtime hours exceeds allowable limits under ● applicable law or agreement : 4% Overall, under BIC two-years-cycle of social audits, 74% of the contract manufacturers were audited. The contracts manufacturers that were not audited during this cycle (especially for operational reasons) will be early 2019.

SOCIAL AUDITS IN THE ADVERTISING AND PROMOTIONAL PRODUCTS BUSINESS

BIC Graphic Europe joined the SEDEX platform in 2012. SEDEX, the Supplier Ethical Data Exchange, is a not-for-profit organization dedicated to driving improvements in responsible and ethical business practices along the supply chain. Being a member of SEDEX provides the added benefit of having a confidential platform for sharing social compliance audit reports and related information and participation in working groups. The SEDEX Members Ethical Trade Audits (SMETA) standard combines several reputable standardization programs including the ILO Convention, ETI (Ethical Trading Initiative) Base Code, SA 8000 and ISO 14001. In 2018, the Tarragona factory (Spain) was audited according to the WCA criteria and earned a score of 100%. The Mexican factories and Conté (France) factories were also audited.

Perspectives ❯ In the years to come, the BIC Group plans to pursue its social audit program, which will be incorporated in the BIC strategy "Writing the Future, Together" and its commitment #4, Proactively involving suppliers (see 3.5.1.1).

Since 2007, the BIC Group Code of Ethics has defined the fundamental ethical principles that the Group asks all of its employees to follow under all circumstances and everywhere in the world. The objective is to build and sustain an authentic corporate culture of integrity, honesty and fairness. The Code of Ethics comprises: 14 standards covering the following aspects: respect for ● fundamental Human Rights, respect for the environment, compliance with the law, listening and communicating, and the prevention of any form of active or passive corruption; 13 principles governing the behavior of BIC employees to ● control risks arising from conflicts of interest, the protection of the Group’s assets, professional commitments, and relationships with its stakeholders; a Guide listing the questions that all BIC employees must ask ● themselves to assess their level of compliance with the Code of Ethics and facilitate its understanding and implementation. The Code of Ethics, as approved by the Board of Directors and the CEO, and its guide are available in 15 languages. The text of the Code is available to all employees on the Group Intranet.

Ethics and the fight against 3.5.1.3. corruption Challenges ❯

BIC generates 32% of its sales in countries where the risk of corruption is considered high or very high (Brazil, Mexico, India, Italy and Argentina) and 68% in countries with a medium or low risk of corruption according to Transparency International, including France, the United States and Spain. Approach ❯ Compliance with ethical principles and the fight against all forms of corruption, active or passive, are stipulated among the standards of the BIC Group Code of Ethics and BIC Group Anti-Corruption Policy .

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• BIC GROUP - 2018 REGISTRATION DOCUMENT •