BIC - 2018 Registration document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Our societal responsibility [NFPS]

Since 2016, the BIC Group Anti-Corruption Policy has defined the appropriate conduct mandatory for all BIC personnel, including employees, Directors and administrators, and for all parties acting on the Group’s behalf: subsidiaries, affiliate companies, partners under contract, wholesalers, consultants… The Policy describes how business must be conducted with third parties to protect against corrupt practices and avoid their occurrence. BIC Group does not tolerate any kind of corruption or bribery and has made a commitment to fight corruption in all of its forms. The Anti-Corruption Policy covers the following topics: interactions with government officials, private entities and ● persons who are not government officials; gifts, corporate gifts and sponsorship; ● relations with stakeholders; ● donations, contributions to communities and political parties; ● conflicts of interest; ● monitoring, record keeping and reporting of any breaches of ● anti-corruption laws. Employees are offered training on the Code of Ethics and the fight against harassment. “BIC Speak Up,” the Group’s anonymous and confidential reporting system, is accessible by telephone and Internet to all current and former BIC employees 24 hours a day and is available in more than 200 languages. BIC is committing to ensure the confidentiality of the information gathered as well as to ensure that no sanction is taken against an employee who reported in good faith a breach of the BIC Group Anti-Corruption Policy or to the Group Code of Ethics. The alert hotline will be accessible to third parties from 2019. This alert mechanism aims to prevent the actions or conducts that would be contrary to integrity, honesty or equity. It is the responsibility of the entities’ CFOs or equivalent Officers to assess the entities’ tax positions and manage all tax filings. The BIC Group Tax Department provides broader support to all entities. In 2018, the internal control procedures did not detect any case of tax evasion linked to the activities of the Group.

Anti-Corruption Policy through e-learning sessions for employees in Africa, the Middle East and the Asia Pacific zone.

Perspectives ❯ In the coming years, further training will be extended to cover additional aspects of compliance. Year after year, the Group will continue to bolster its mechanisms for upholding ethics and fighting corruption.

3.5.2.

SUPPORTING THE LOCAL

ECONOMY AND PROMOTING SOLIDARITY Generating and maintaining jobs 3.5.2.1. Approach ❯ BIC Group participates directly and indirectly in the local economy in every region where it has operations. Every time it starts operations in a new region, BIC’s policy is to favor local hiring over expatriation. As a result, the Group has a total of only 88 expatriated employees today (0.64% of permanent employees). BIC thus contributes directly to local economies by generating jobs. Historically located in Europe, BIC has been developing and maintaining industrial jobs in this region, in particular in France, Spain and Greece, for several decades. The Group promotes “Made in France” and “Made in Europe” products in its catalogs, thus contributing to the creation of value and jobs in these countries, which have been especially hard hit by the economic crisis that began in 2008. BIC values the local manufacturing of its products so that it contributes to local economic development and includes the local communities in the value chain. The Group has strongly localized its manufacturing operations, especially via a network of six licensed factories solely for the Middle East-Africa zone. This local partnership approach has brought BIC ® products closer to its consumers, making them more affordable and minimizing transportation costs. There are multiple benefits for the partners and the communities alike, especially in local job creation, technology sharing and transfers, and enhanced product competitiveness.

Progress made in 2018 ❯

In 2018, BIC carried out an evaluation of its risks related to third parties. The Group continued to strengthen its ethics program and efforts to fight corruption, expanding its mandatory training on the

ECONOMIC IMPACT STUDY ON THE BIC FACTORY IN MANAUS (BRAZIL)

A pilot study conducted in 2004, and discussed in detail in the BIC Group 2005 Sustainable Development Report, provides a better understanding of the impact of the activities of a BIC site on the local economy in a developing country. The findings showed that in the city of Manaus, which is located in a very remote region (the Amazon) where industry is concentrated in just a few sectors, only a quarter of the site’s expenditures remained locally in Manaus, with the remaining expenditures going to the rest of Brazil and foreign countries. In terms of employment, the study showed that each direct job at BIC Amazonia generated up to three local jobs and indirectly supported as many as 10 people just in the city of Manaus. Since 2004, Brazil has opened its economy to more foreign investment and improved its economic and transportation infrastructures. As a result, the findings of this study would no doubt be somewhat different today, but Manaus remains a remote, isolated site.

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• BIC GROUP - 2018 REGISTRATION DOCUMENT •