BIC - 2019 Universal Registration Document

RISKS MANAGEMENT

Description and mitigation of main risk factors

Risks related to counterfeiting/Gray Goods, Parallel Imports and Non-compliant Products from competition

Counterfeits of the most well-known BIC products circulate, principally throughout Africa, the Middle East, Eastern Europe, and South America. They are mostly produced in Asia. These counterfeits, often of low quality, are mainly focused on the shape of our products and on the BIC ® trademark. Gray good products that violate U.S. regulations pose product recall risks. The Group is confronted with competition from low-cost lighters that in Europe often do not comply with safety standards, the ISO 9994 international safety standard, and the EN 13869 child resistance standard.

Level of risk: medium Potential impact on BIC:

Examples of Risk Mitigation:

Impact on the Brand image (Consumers), and business interests.

BIC, through its Legal Department, fights against these counterfeits, working in close cooperation with local authorities, law enforcement agencies and initiating court and administrative actions, enforcing a monitoring program of leading e-commerce platforms, market surveillance, traceability measures, and collaborating with local authorities to better prevent illegal diverting of gray goods to the U.S. BIC fights against non-compliant lighters through communication activities, informing the different stakeholders (customers, market surveillance authorities, EU Commission, EU Parliament, etc.). The Group has launched legal actions, the latest being filings before the European Commission in October 2018, requesting the opening of infringement procedures against France and Germany, after the Netherlands in 2010. In 2019, the Group continued to contribute to public consultations launched by the EU Commission, aiming at improving market surveillance rules and their enforcement.

Risks related to increased regulations

Restrictions, prohibitions and prohibitions projects are more and more numerous in the fields of chemical substances as well as plastics, particularly in North America and Europe

Level of risk: medium Potential impact on BIC:

Examples of Risk Mitigation:

Impact on manufacturing processes and business interests.

BIC closely monitors announced regulatory changes and voices relevant technical and legal arguments. For example: BIC filed an objection in Court against the Spanish Valencian region • Decree banning non-refillable shavers and is making proposals to improve the relevance of new laws, as was the case with the law of the Balearic Islands regarding certain plastic products; BIC, together with other European manufacturers, continues to object • to the EU Commission’s interpretation of the scope of the EU’s CLP regulation, which would require the labeling of each writing instrument and lighter with warning phrases relating to chemical substances in containers.

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •