BIC - 2020 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 has 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 BIC Group Anti-Corruption Policy (updated in October 2020), the new BIC Group Code of Conduct (issued in 2020 and which regroups the former Code of Ethics and Code of Conduct), Health, Safety,

Environment Policy (EH&S), the BIC Charter of Diversity, The Supplier Code of Conduct (issued in 2020), the Global Procurement Policy (issued in 2020) the Responsible Purchasing Charter (incorporated in the Supplier Code of Conduct (issued in 2020). 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 § 3.2.1 Our products’ environmental performance.

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 teammembers 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 § 3.3.1Writing The Future, Together – §2 Acting against climate change.

Product safety and Consumer Health and Safety Health and Safety of Teammembers

Risks for people health and safety

BIC policies for product safety

See the product safety policy in § 3.2.2 Product safety.

Risks for people health and safety

2025 Commitment: #3 Committing to a safe work environment. EH&S Policy BIC Code of Conduct, HR Policies

See the process of safety in the workplace in § 3.4.3 Health/Safety in the workplace.

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

Risks on Human Rights and Fundamental Freedoms

See the measures for the respect of Human Rights in the workplace in § 3.5.2 Ensuring respect for human rights in the workplace. See the anti-corruption fight process in § 3.5.3 Ethics and the fight against corruption.

Unfair practices (Corruption)

Risks of active or passive corruption

BIC Code of Conduct and BIC Anti-Corruption Policy

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• BIC GROUP - 2020 UNIVERSAL REGISTRATION DOCUMENT •

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