BIC - 2019 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Responsibility concerning our products [NFPS]

BIC’S SEVEN COMMITMENTS TO ENSURE THE QUALITY AND SAFETY OF ITS LIGHTERS

1. All BIC ® lighter plants are ISO 9001 certified production plants. BIC ® lighter products meet or exceed the ISO 9994 international safety standard requirements. 2. BIC is an active member of various organizations (such as the European Federation of Lighter Manufacturers, working groups and technical committees for ISO and CEN and numerous other national standardization bodies) to provide the latest and most reliable quality and safety information to its customers. 3. Each BIC ® lighter undergoes more than 50 separate automatic quality checks. Additionally, BIC conducts regular post-market product tests of its lighters. 4. BIC continuously develops and improves exclusive technology to ensure the quality and safety of all BIC ® lighters, including factors like flame height and stability, extinction time, and a reservoir that can resist extreme drop tests and exposure to elevated temperatures. 5. BIC has an integrated production process, designs and develops much of its own machinery and uses all the latest manufacturing technologies, from basic materials right down to the packaged lighter. 6. BIC employees are all guided by three principles: Method-Precision-Discipline. Each employee in the lighter plants spends nearly 25% of his or her time checking product conformity and proper operation of the control equipment. 7. BIC has been committed to sustainable, long-term safety programs for over 30 years.

Actions taken  [NFPS] 3.2.2.3 Regulatory monitoring and compliance

substances to be restricted or replaced in BIC ® products by 2025. The evaluation involved 249 product ranges, 443 formulas and 45 specific tests. BIC, as a member or Executive Committee member of numerous sectoral organizations and industry associations  (1) , actively participates in regulatory watch and interactions with local regulatory authorities, an important activity for staying abreast of new requirements. In order to keep pace with future regulatory challenges, in 2019 the Product Safety teams participated in various events in Europe and around the world on themes concerning the safety of cosmetics, chemicals and consumer goods, in particular : Congrès Parfums et Cosmétiques , Chemsec, REACH Conference DII, The International Consumer Product Health and Safety Organization. To comply with the CLP regulation, BIC began preparing for the EU toxicovigilance statements and the adoption of the UFI (Unique Formula Identifier) number on the packaging of its products covered by the regulation.

BIC has a comprehensive monitoring system based on formalized regulatory watch procedures in addition to internal and external resources –  in particular, the product safety teams’ specific knowledge of BIC ® products, their components and the materials used. In 2018, a BIC Watch List was created to extend the Group’s monitoring system to include non-official lists defined by NGOs, future regulations and controversial substances that are not already banned. The Group always strives to anticipate the substitution of regulated substances. By its very nature open-ended, this Watch List will be expanded to include requirements and controversies reported from outside of Europe. In 2019, the BIC Watch List was made more operational for the work teams and more precise, targeting risks related to BIC ® products and the Group’s customers. During the large-scale product evaluation campaign conducted in 2019 as part of commitment #1 of “Writing the Future, Together,” the BICWatch List was used to establish an overview of the current situation, identifying directions for improvement concerning

COMPLIANCEWITH THE REACH REGULATION

The European REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) regulation establishes the regulatory framework for chemical substances and places responsibility on manufacturers to demonstrate the safety of the chemicals they use. To address these requirements, BIC created a dedicated organization to allow the integration of the REACH topics. At Group level, an expert was appointed who, with the support of specialized firms, monitors the regulation, evaluates the impacts for the Group and creates the administrative files. This person is the contact person for all entities on this topic. Since 2008, in response to REACH, BIC has preregistered 168 substances for six of its legal entities. In compliance with the law, registration has been completed for all substances that needed to be registered. After the deadline of 2018 for products representing 1 to 100 tons per year, the authorities are now evaluating the compliance of the registration files received. BIC remains on the lookout for potential impacts on the files submitted.

In particular, BIC is a member of EWIMA (European Writing Instrument Manufacturers Association), WIMA (Writing Instrument Manufacturers (1) Association), ACMI (Art & Creative Materials Institute), TIE (Toy Industries of Europe), EFLM (European Federation of Lighter Manufacturers), and the Fédération des Entreprises de la Beauté in France.

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• BIC GROUP - 2019 UNIVERSAL REGISTRATION DOCUMENT •