BIC - 2019 Universal Registration Document

RISKS MANAGEMENT

Description and mitigation of main risk factors

Risk related to the non-respect of Human Rights and Unfair Practices

Non-compliance with fundamental human rights such as child labor, discrimination or forced labor. • Corruption and unfair practices. •

Level of risk: medium Potential Impact on BIC:

Examples of Risk Mitigation:

Legal action against BIC and major consequences in terms of reputation and attractiveness.

To ensure respect for Human Rights at work, BIC has adopted a Code of Conduct, consisting of a set of professional and social principles derived from the standards of the International Labor Organization (ILO). The Group is committed to socially responsible behavior in all its activities. The Code of Conduct applies to BIC factories as well as contract manufacturers and its implementation is regularly monitored by BIC through audits and tools. Moreover, BIC’s reliance on contract manufacturing is relatively low. Overall, 92% of its net sales are generated by products made in its own factories. 87% of its factories are located in countries with no Human Risk, according to FreedomHouse. The Group works with subcontractors primarily for Stationery products in the Consumer business and for Advertising and Promotional Products. Subcontracting gives BIC greater flexibility. More information is available in section 3.5 of Chapter 3 Our environmental, social and societal responsibility (§ 3.5.1.2 Ensuring respect Human Rights in the workplace) . Compliance with ethical principles and the fight against all forms of corruption, active or passive, are stipulated among the standards of BIC Code of Ethics and BIC Anti-Corruption Policy. Since 2007, BIC Code of Ethics has defined the fundamental ethical principles that the Group asks all of its teammembers 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. Since 2017, BIC has been developing and deploying tools (training, reporting systems, etc.) to facilitate the identification, evaluation, mitigation, monitoring and quantification of the potential risks of corruption and unfair practices. More information on the fight against corruption is available in Chapter 3, section 3.5 (§ 3.5.3 Ethics and the fight against corruption) .

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •