BIC - 2019 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Responsibilities related to our supply chain [NFPS]

An approach guided by the BIC Code of Conduct To ensure respect for Human Rights in the workplace, BIC has implemented a Code of Conduct. This document comprises a set of professional and social principles derived from the standards of the International Labor Organization (ILO). The Group is committed to upholding socially responsible behavior in all its operations. The principles in this document are applied at all production facilities, whether owned by the Group or operated by contract manufacturers, and BIC conducts audits to ensure its implementation. The Code of Conduct is based on the following 10 principles: a safe and healthy work environment; ● fair wages and reasonable working hours; ● no child labor; ● no forced labor; ● no discrimination; ● freedom of association; ●

more than 15 years to ensure compliance with its Code of Conduct by contract manufacturers. The program applies to both global contract manufacturers and contract manufacturers under local contracts producing BIC ® products for local markets for BIC Consumer Products and BIC Graphic (Advertising and Promotional Products). Regular audits are conducted every two years to verify that standards are maintained at a satisfactory level. Audits are carried out by third party Auditors. In 2014, BIC Group introduced the Workplace Condition Assessment (WCA) platform. This assessment tool is based on national laws, integrating ILO standards and existing best practices, and is consistent with the Group Code of Conduct. The WCA comprises more than 180 evaluation criteria covering a range of topics: child labor, forced labor, discrimination, harassment, freedom of association, working hours, salaries, employment contracts, health and safety and environmental responsibility. Contract manufacturers are audited and rated on each criterion and then given an overall score. This platform allows the Group to closely monitor a contract manufacturer’s performance in relation to each indicator. Deficiencies in each evaluation criterion are rated as major, moderate or minor, thus allowing the implementation of targeted corrective action plans where needed. It also includes global benchmarks for each country and each Group business sector. All contract manufacturers producing BIC ® products are audited over a two-year cycle, during which improvement programs will be implemented based on deficiencies identified during the assessment. BIC sees social responsibility as a partnership that requires shared values. In this spirit, BIC favors a common commitment to improvement rather than breaking off relations with a partner. The box below explains the main steps in the evaluation of contract manufacturers. Self-assessments were conducted by all BIC factories from 2006 through 2016. The Group was thus able to acquire a thorough understanding of the risks and to develop corrective action plans in cooperation with the Human Resources Department.

legal compliance; ● no animal testing; ● environmental responsibility; ● publication of the Code. ●

This Code of Conduct applies to BIC factories, which are mainly located in South Africa, Brazil, Spain, the U.S., France, Greece, India and Mexico. It also applies to contract manufacturers, which are primarily located in China, Brazil and Vietnam.

3.5.2.3

Actions taken: the social audit

program  [NFPS]

Compliance with the Code of Conduct is verified by an audit program covering all the factories where BIC ® products are manufactured. BIC has had a specific audit program in place for

THE SIX STEPS FOR EVALUATING CONTRACT MANUFACTURERS

1. The BIC contract manufacturer signs the BIC Code of Conduct. 2. An independent external monitoring agency conducts an initial assessment of the contract manufacturer. 3. BIC presents a corrective action plan (CAP) to the contract manufacturer. 4. The contract manufacturer implements the CAP within an agreed upon, reasonable time frame. 5. The Auditor conducts follow-up assessment(s) to confirm implementation of the CAP. 6. Ongoing assessments are conducted every two years.

3.5.2.4

Results of the social audit program and

that support adherence to social compliance requirements but they are not all being properly implemented: 5%; 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: 4%; total overtime hours exceeds allowable limits under applicable ● law or agreement: 4%.

perspectives  [NFPS] In 2019, 35 contract manufacturers (for Consumer Products or BIC Graphic) were audited, representing 43% of our active contract manufacturers at year end. The audits directly requested and managed by BIC, revealed, 34 major, 189 moderate and 166 minor deficiencies, and 34 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

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •