BIC - 2020 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Ethics and business conduct across the value chain [NFPS]

THE SIX STEPS FOR EVALUATING CONTRACT MANUFACTURERS

The BIC contract manufacturer signs the BIC Code of Conduct. 1. An independent external monitoring agency conducts an initial assessment of the contract manufacturer. 2. BIC presents a corrective action plan (CAP) to the contract manufacturer. 3. The contract manufacturer implements the CAP within an agreed upon, reasonable time frame. 4. The Auditor conducts follow-up assessment(s) to confirm implementation of the CAP. 5. Ongoing assessments are conducted every two years. 6.

Between 2019 and 2020, 31 contract manufacturers (Consumer Products or BIC Graphic) were audited, representing 58% of active contract manufacturers.

3.5.3

BUSINESS CONDUCT AND THE FIGHT AGAINST CORRUPTION [NFPS]

Regardless of their role, seniority or location, all team members are required, at all times, to comply with this Code, the Group’s policies and standards, and all applicable laws, regulations and industry standards that relate to their individual work. The new BIC Code of Conduct covers the following topics: protecting the integrity of the BIC Group and strengthening ● its reputation: conflicts of interest, gifts and entertainment, bribery and corruption, relations with governments and political bodies, brand protection, competition, money laundering, trade controls; valuing and respecting employees: health and safety, ● discrimination and harassment, Human Rights; protecting data, assets and information: information ● technology security, company property and resources, data privacy and personal information, business records; maintaining high quality relationships and partnerships ● with all stakeholders: quality, environment, charitable contributions, external communications and social media, relationships with customers, suppliers and other business partners. On each topic, a concrete situation or question is proposed and the right attitude to adopt is described. With this update, the BIC Code of Conduct now covers the topics previously covered by the Code of Ethics. The Supplier Code of Conduct (see 3.6.1.1 ) and the Anti-Corruption Policy (see below) are a vital part of this Code concerning these specific topics. This updated Code of Conduct was distributed to all employees in October 2020. It has been translated into seven languages – English, Spanish, French, Greek, Hindi, Portuguese and Russian – and is available on the BIC Intranet, the central information hub for all team members worldwide, as well as the website www.bicworld.com. Training sessions on the Code of Conduct and the Anti-Corruption Policy were launched in October 2020. All employees have been invited to attend these training sessions to ensure a complete and comprehensive understanding of the Code.

BIC generates 20% of its sales in countries where the risk of corruption is considered high or very high (Brazil, Mexico, India, Italy and Argentina) and 80% in countries with a medium or low risk of corruption according to Transparency International, including France, the United States and Spain. 3.5.3.1 [NFPS risk 6] Among its main CSR risks, BIC has identified risks related to corruption: the risk of corruption and unfair practices can lead to legal actions against the Group and major consequences in terms of reputation and attractiveness. Risks [NFPS] The BIC Code of Conduct As compliance laws change, the BIC Group is evolving its internal policies and directives to keep pace with the legal and regulatory environment. Thus, the Code of Ethics (2014) was reviewed and updated in 2020 to incorporate the Group’s vision, mission and updated Values, as well as best practices in Codes of Conduct and all necessary updates to ensure that the team members are able to take ownership of this legal and regulatory context. This update has taken the form of a new BIC Group Code of Conduct. Part of BIC’s ongoing monitoring of compliance measures, the new Code outlines: the expectations of how BIC’s business is to be conducted; ● the Group’s Vision, Mission and Values; ● proper behavior toward internal and external stakeholders; ● precepts on integrity that focus on the Values being applied in ● the workplace; and guidance on where employees can find relevant policies, ● procedures and guidelines. Policy, actions taken, results 3.5.3.2 and perspectives [NFPS]

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• BIC GROUP - 2020 UNIVERSAL REGISTRATION DOCUMENT •