BIC - 2018 Registration document

RISKS

Risk management and internal control procedures implemented by the Company Risk management and internal control procedures

Team members 2.4.3.6. Each team member is involved in the internal control processes in accordance with his/her respective knowledge, and has access to the information used to design, operate and monitor the internal control system. The Group Internal Control Policies including the Group Controllers’ Manual are available online for team members with access to the Group Intranet. To reinforce the commitment of all team members to the importance of internal control in the Company, the Values of the BIC Group are posted at all Group locations so that all team members have access to them. In 2018, all BIC sites participated in the company-wide engagement survey. This survey covers multiple aspects of engagement and also assesses our adherence to our company values. Over 11,000 team members were invited to participate, encompassing 59 countries. In 2018 the response rate increased to 93% compared to 84% in 2016. Overall employee engagement was favorably assessed at 84%, representing strong engagement at 4.5% above the market norm. Significant drivers of overall engagement focused on favorable assessment of willingness to stay with BIC and recommending BIC as a good place to work. This year a question on Diversity and Inclusion was added to the survey to gauge whether our team members believe BIC is a diverse and inclusive work environment. This question was answered favorably at 82%. The Values questions showed very favorable responses overall and were specifically strong with respect to the values of Responsibility and the application of Ethics. This reaffirmed the efforts taken in 2017 to reengage our team members on the importance of the principles behind the Group Code of Ethics. The BIC Group Code of Ethics is available for all team members on the Group Intranet. The Code of Ethics and its guide were updated in 2014. The Board of Directors has taken note of it and reaffirmed, as necessary, the importance of the action and behavior principles mentioned in this Code. The Leadership Team validated the Group Code of Ethics and related procedures and policies and distributes it throughout the BIC Group. A Group Anti-Corruption Policy was also made available to all team members on the Group Intranet in 2016, stating that the BIC Group prohibits bribery and corruption in any form and upholding our reputation for integrity. In 2017, the BIC Group also launched its Anti-Corruption and Code of Ethics e-learning, which was completed by most team members in all BIC markets. Since July 2017, the BIC Group has partnered with an independent provider to manage a new phone and internet-based reporting system called BIC Speak-up, which provides an alternative channel for team members to communicate their concerns confidentially and anonymously if they so choose (and where permitted by local law). This program has been established to provide effective lines of communication from team members and empowers BIC to promote safety, security, and ethical behavior. Additionally, a Charter of Diversity was signed in 2011. This Charter of Diversity, shared by all the entities, defines the BIC Group

commitment to continually improving and educating team members about the importance of diversity and aims to assist in the prevention of discrimination in the workplaces.

2.4.4.

INSURANCE – COVERAGE OF RISKS LIKELY TO BE INCURRED BY THE ISSUER

On behalf of all its entities, the BIC Group purchases the following global insurance programs: “Commercial General Liability” insurance including risks ● related to products; “Environmental Impairment Liability” insurance related to ● gradual pollution and accidental pollution; “Property Damage and Business Interruption” insurance ● covering all locations; “Goods-in-Transit” insurance for goods and products while in ● transit. The objective of the BIC Group’s insurance programs is to develop a uniformly high level of risk management and insurance protection for all the BIC operating entities. This policy should help protect assets and, therefore, revenue, against risks that may be insurable or controllable. It is BIC’s intent to control risk through effective risk management techniques, as well as insurance and loss prevention policies in order to meet its long-term objectives of continuous operation, growth and profit. Management believes that coverage and limits of these insurance programs are appropriate. In 2015 and 2016, an analytics project confirmed that the coverage, limits and premiums of most BIC Group’s insurance programs are adequate. Moreover, Requests For Proposals (RFP) are regularly launched on all Group insurance programs in order to obtain the best coverages possible. Indeed, in 2018, for the 01-Jan-2019 renewal of its “Property Damage and Business Interruption” program, the BIC Group launched a major RFP which confirmed that the structure and insurer of the BIC program meet the Group’s needs and that it is financially efficient. The BIC Group believes in the risk management process as a means of protecting its assets from the adverse effects of accidental loss. That is the practice of identification, analysis and management of all risks in relation to its operations. It is essential that all Group entities are involved. Whenever we can exercise effective loss prevention and loss control, BIC accepts to retain a portion of the risk. While relying on a proactive approach to risk management for the protection of its assets, the Group nevertheless maintains insurance policies to guard against catastrophic loss, or in some cases, the likely risk of loss. By meeting the above criteria, BIC’s assets and profitability should be protected to the greatest extent possible. The global cost estimate of the BIC Group insurance programs to third-party insurers amounts to approximately 3.7 million euros.

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• BIC GROUP - 2018 REGISTRATION DOCUMENT •