BIC - 2020 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Ethics and business conduct across the value chain [NFPS]

The Supplier Code of Conduct See § 3.5.1.1 .

PERMANENTWORKFORCE BY CATEGORY OF COUNTRY IN RELATION TOHUMAN RIGHTS RISK (1) IN 2020 – BIC GROUP

2% Not free countries

13% Partly free countries

The social audit program [NFPS] Compliance with the Code of Conduct (see below) is verified by an audit program covering all the factories where BIC ® products are manufactured. BIC has had a specific audit program in place for more than 15 years to ensure compliance with its Code of Conduct by contract manufacturers. The program applies to both global contract manufacturers and contract manufacturers under local contracts producing BIC ® products for local markets for BIC Consumer Products and BIC Graphic (Advertising and Promotional Products). Regular audits are conducted every two years to verify that standards are maintained at a satisfactory level. Audits are carried out by third party Auditors. In 2014, BIC Group introduced the Workplace Condition Assessment (WCA) platform. This assessment tool is based on national laws, integrating ILO standards and existing best practices, and is consistent with the Group Code of Conduct. The WCA comprises more than 180 evaluation criteria covering a range of topics: child labor, forced labor, discrimination, harassment, freedom of association, working hours, salaries, employment contracts, health and safety and environmental responsibility. Contract manufacturers are audited and rated on each criterion and then given an overall score. This platform allows the Group to closely monitor a contract manufacturer’s performance in relation to each indicator. Deficiencies in each evaluation criterion are rated as major, moderate or minor, thus allowing the implementation of targeted corrective action plans where needed. It also includes global benchmarks for each country and each Group business sector. All contract manufacturers producing BIC ® products are audited over a two-year cycle, during which improvement programs will be implemented based on deficiencies identified during the assessment. BIC sees social responsibility as a partnership that requires shared values. In this spirit, BIC favors a common commitment to improvement rather than breaking off relations with a partner. The box below explains the main steps in the evaluation of contract manufacturers.

85% Free countries

CONTRACT MANUFACTURERS BY CATEGORY OF COUNTRY IN RELATION TOHUMAN RIGHTS RISK (1) IN 2020 – BIC GROUP

8,5% Partly free countries

33% Free countries

58,5% Not Free countries

Source: Freedom House. (1)

123

• BIC GROUP - 2020 UNIVERSAL REGISTRATION DOCUMENT •