BIC - 2020 Universal Registration Document

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY

Our products [NFPS]

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. Many countries are adopting regulations similar to the EU REACH regulation. As of end December 2020, BIC has pre-registered 19 substances for South Korea, 141 for Eurasia (Armenia, Belarus, Kazakhstan, Kyrgyzstan and Russia) and 30 substances for Turkey.

Marketing compliant products that are safe for human health and the environment To guarantee consumer safety, the Group Insights & Innovation Officer, the Group Supply Chain Officer and the Group Lighter General Manager are responsible for marketing safe products that comply with regulations. To this end, they rely on: BIC Group’s commitment to ensure that its products comply ● with regulations and are safe for health and the environment (see above); monitoring by dedicated regulatory watch teams (see above); ● a product safety qualification process for all products before ● they are launched in the market (see below). This solid, longstanding organization is constantly being adapted and expanded to take changing regulations into account. The Executive Committee and management teams are systematically kept abreast of new developments in product safety and regulations. In 2020, in response to the recommendations and exemptions issued by the relevant authorities, BIC undertook qualification for the production of masks and hydroalcoholic gels at its sites. These products were manufactured for the protection of the Group’s own employees and for donations. [Covid-19] In addition, the lockdown measures imposed in France from March to May 2020 obliged the Product Safety teams to reorganize the management of samples in order to compensate for the closing of some laboratories and maintain the product qualification processes. Systematic testing and evaluation programs Before they arrive on the market, all BIC ® products, whether new or modified, must undergo a comprehensive program of safety tests and qualification evaluations. These tests and evaluations make it possible to assess potential hazards and to identify the chemical substances present, evaluate their risk level, verify their compliance with standards, and identify any adaptations of the formulas or substitutions that might be needed to reduce risks.

BIC faces competition from several low-cost lighters that too often do not comply with international safety standards. According to tests conducted by independent accredited laboratories, more than three quarters of the lighter models in the European market fail to meet standards. The Group has initiated actions to raise awareness among the various parties involved. In 2010, emphasizing the consequences for consumer safety, BIC filed a complaint against the Netherlands with the European Commission for non-enforcement of EU safety standards for lighters. As a result, the Commission opened an infringement procedure against the Netherlands. In March 2012 and then in July 2014, the country was served formal notice to explain its failure. In April 2019, the Association des Brûlés de France (French burn victims’ association) participated in a hearing with the European Parliament after petitioning the European Commission regarding the lack of progress in the regulatory compliance of lighters in Europe. In 2020 the European Commission decided to terminate the infringement proceedings against the Netherlands, as well as the complaints filed by the BIC Group in 2018 against France and Germany for non-enforcement of safety standards on the lighters market. The European Commission is now in the process of revising its General Product Safety Directive, and the BIC Group, based on its knowledge of the market and long experience with the shortcomings of the system, in particular as a result of the infringement proceedings against the Netherlands, is formulating constructive proposals for the fundamental improvement of the European framework for product safety supervision.

291 products have been tested by independent laboratories (1) .

Product qualification excluding lighters. (1)

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• BIC GROUP - 2020 UNIVERSAL REGISTRATION DOCUMENT •