BIC_REGISTRATION_DOCUMENT_2017

GROUP PRESENTATION Risk management and internal control procedures implemented by the Company

To reinforce the commitment of all employees to the importance of internal control in the Company, the Values of the Group are posted at all Group locations so that all employees have access to them. In 2005, the Group Vision and Values were updated and presented to all employees. Since 2005, a survey on the application of the Values across the Group, supplemented since 2010 by an engagement survey, are carried out biannually. In 2016, the engagement survey and the survey on the Values were merged. 84% of invited employees participated in the survey and the engagement was stable at 83%, confirming the interest of employees in this type of initiative and their willingness to share their opinions. The next Opinion Survey will take place in 2018. The Group Code of Ethics is available for all employees on the Group Intranet. The Code of Ethics and its guide were updated in 2014. The Board of Directors has taken note of it and reaffirmed, as necessary, the importance of the action and behavior principles mentioned in this Code. The Leadership Team validated the Group Code of Ethics and related procedures and policies, and distributes it throughout the Group.

A Group Anti-Corruption Policy was also made available to all employees on the Group Intranet in 2016, stating that the Group prohibits bribery and corruption in any form and upholding our reputation for integrity. In 2017, the Group also launched its Anti-Corruption and Code of Ethics e-learning, which was completed by most employees in all BIC markets. Since July 2017, the Group has partnered with an independent provider to manage a new phone and internet-based reporting system called BIC Speak-up, which provides an alternative channel for team members to communicate their concerns confidentially and anonymously if they so choose (and where permitted by local law). This program has been established to provide effective lines of communication from team members and empowers BIC to promote safety, security, and ethical behavior. Additionally, a Charter of Diversity was signed in 2011. This Charter of Diversity, shared by all the entities, defines the Group commitment to continually improving and educating employees about the importance of diversity and aims to assist in the prevention of discrimination in the workplaces.

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BIC GROUP - 2017 REGISTRATION DOCUMENT