BIC - 2019 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Responsibilities related to our supply chain [NFPS]

Perspectives ❯ In the years to come, BIC 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.

contract, wholesalers, or 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. Team members 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 team members 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 a team member who reported in good faith a breach of the Group Anti-Corruption Policy or of the Group Code of Ethics. Additionally, as part of BIC’s continuing efforts to ensure compliance with the Group Anti-Corruption Policy, the Group Code of Ethics and other legal and ethical policies, the alert hotline became accessible to third parties in 2019. The alert hotline is featured on the home page of the BIC Intranet, the central hub of information for all team members worldwide. It is now being improved and updated for easier accessibility. 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 Group Tax Department provides broader support to all entities. In 2019, the internal control procedures did not detect any case of tax evasion linked to the activities of the Group. 3.5.3.3 In 2019, BIC continued to expand its mandatory training programs on ethics and the fight against corruption. An e-learning module is online and live training sessions are offered for team members in Latin America, Africa, the Middle East and the Asia Pacific Zone. In the years to come, BIC will continue to enhance its third-party risk management, relying on the supplier risk management mechanisms already in place and extending its due diligence, risk assessments and risk mitigation measures for key customers. Additionally, new training programs will be introduced by BIC to cover other aspects of compliance, in particular duty of care, the fight against anti-competitive practices and data privacy. Actions taken and perspectives  [NFPS]

3.5.3

ETHICS AND THE FIGHT AGAINST

CORRUPTION  [NFPS]

3.5.3.1

Challenges and risks related to ethics

and the fight against corruption  [NFPS] 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. [NFPS risk 6] Among its main CSR risks, BIC has identified risks related to corruption: the risk of corruption and unfair practices can lead to legal actions against the Group and major consequences in terms of reputation and attractiveness. Since 2007, the Group Code of Ethics has defined the fundamental ethical principles that the Group asks all of its team members 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 team members 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 team members 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 teammembers on the Group Intranet. Ethics and anti-corruption policies  [NFPS] 3.5.3.2 BIC Code of Ethics

BIC Anti-Corruption Policy

Since 2016, the Group Anti-Corruption Policy has defined the appropriate conduct mandatory for all BIC personnel, including team members, managers or Directors, and for all parties acting on the Group’s behalf: subsidiaries, affiliate companies, partners under

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •