BIC - 2019 Universal Registration Document

RISKS MANAGEMENT

Vigilance Plan

2.3.4

ORGANIZATION ANDMEASURES FOR THE PREVENTIONOF MAJOR

NON-FINANCIAL RISKS

The tables below refer to the pages of Chapter 3 of the registration document which gives a detailed presentation of the issues, the policies, the initiatives, the accomplishments of the past year and the extra-financial performance of the BIC Group. BIC implemented a body of documents to facilitate risk management. Those that address the topics covered by Law and provide the basis for the BIC Group’s Vigilance Plan are: The Code of Ethics, the BIC Group Anti-Corruption Policy, the BIC Group

Code of Conduct, Health, Safety, Environment Policy (EH&S), the BIC Charter of Diversity, the Responsible Purchasing Charter. These documents are listed in part 3.1.2. Our Policies. Within the scope of the Law, the major risks listed below correspond to the most critical risks identified (resulting from the probability of occurrence and the significance of the potential impacts regarding the applicable risks).

A.

Major risks arising from BIC Group activities  [NFPS]

Mitigation and remediation measures/Due diligence and regular assessment processes/Results – Key extra-financial performance indicators See the eco-design process in section 3.2.1 Our products’ environmental performance (pages 77 à 82).

Major risks

Type of risks

BIC Policies

BIC Organization

Plastics: plastic waste and resource depletion

Environmental risk

2025 Commitment: #1 Fostering sustainable Innovation in BIC ® products

Implementation by the Categories, by the Purchasing Department, with the support of the Sustainable Development Department Implementation by the Sustainable Development Department EH&S Officer in each factory Implementation by the Product Safety Department Implementation by HR and each category EH&S Officer in the factories Implementation by HR for team members Implementation by each Factory Director Implementation by an Anti-Corruption Officer, the Legal Department, the Purchasing Department

Climate change

Environmental risks

2025 Commitment: #2 Acting against climate change

See the process of fight against climate change in section 3.3.1 Writing The Future, Together – #2 Acting against climate change (pages 88 à 92).

Product safety and Consumer Health and Safety Health and Safety of Team members

Risks for people health and safety

BIC policies for product safety

See the product safety policy in section 3.2.2 Product safety (pages 82 à 84).

Risks for people health and safety

2025 Commitment: #3 Committing to a safe work

See the process of safety in the workplace in section 3.4.3 Health/Safety in the workplace (pages 98 à 100).

environment EH&S Policy

Non-respect of Human Rights and Fundamental Freedoms (child labor, ILO conventions)

Risks on Human Rights and Fundamental Freedoms

Code of Ethics, HR Policy

See the measures for the respect of Human Rights in the workplace in section 3.5.2 Ensuring respect for human rights in the workplace (pages 109 à 111).

Code of Conduct

Unfair practices (Corruption)

Risks of active or passive corruption

BIC Group Code of Ethics and Anti-Corruption policies

See the anti-corruption fight process in section 3.5.3 Ethics and the fight against corruption (page 111).

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •