BIC_REGISTRATION_DOCUMENT_2017

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY The BIC Sustainable Development Program

Risk factors At this stage, the risk mapping has involved identifying for each topic of the law (Human Rights, Fundamental freedoms, Health and Safety of people and Environment) the type of risks that are significant in BIC's activity (factories or offices) and its suppliers and subcontractors (geographic, operational or sector risk). Identification of the most pertinent approaches for assessing risk criticality was initiated. These approaches, as they stand today, are listed in the following table. This effort will be pursued in greater depth in 2018.

Human Rights and Fundamental Freedoms

Health & Safety and Environment

BIC Group factories

Geographic approach

Operational approach

BIC Group offices

Geographic approach

Subcontractors

Geographic approach and operational approach Geographic approach and operational approach

Raw materials suppliers

Transport companies

Geographic approach and sector approach

Other service providers

Geographic approach

The geographic approach takes into account the risks associated with each country, primarily based on the indices published by NGOs like the International Federation for Human Rights (FIDH) and Freedom House. The operational approach takes into account the intrinsic risks for each factory. The sector approach takes into account the specific risks for the sector concerned (e.g. transport). Risk assessment Risks will be assessed as the result of the probability of occurrence and the severity of the potential impact in relation to the applicable risk factors. Organization and measures for the prevention ♦ of infringements of human rights and fundamental freedoms, dangers to the health and safety of people and environmental damage Framework documents The Group has compiled a body of documents to facilitate risk management. These documents are listed in Section 2.1.4.3

(“Our Policies”). Those that address the topics covered by law and provide the basis for the BIC Group’s vigilance plan are: the Code of Ethics, the BIC Group Anti-Corruption Policy, the BIC Group Code of Conduct, the Environment, Health & Safety (EH&S) Policy, the BIC Charter of Diversity and the Responsible Purchasing Charter. Organization and measures implemented At this stage, the work on the vigilance plan has involved identifying the policies and measures already implemented by the Group to manage and mitigate identified risks and record the gaps that should be filled in implementing the vigilance plan. The tables present an overview of the current state. The page numbers in parentheses direct the reader to Chapter 2 of the Group’s registration document, “Our environmental, social and societal responsibility,” which gives a detailed presentation of the BIC Group’s issues, policies, initiatives, accomplishments of the past year and performances in sustainable development. It covers the topics specifically covered by law.

HUMAN RIGHTS AND BASIC FREEDOMS - RISK MANAGEMENT METHODS AND MEASURES IMPLEMENTED

Risk management tools and organization

Mitigation and remediation measures Hotline “BIC Speak-Up” (p.91) Social dialog (p.84) Hotline “BIC Speak-Up” (p.91) Social dialog (p.86)

Policy

BIC Group factories

Code of Ethics (p.91) Code of Conduct (p.89)

Self-evaluations (p.90)

BIC Group main offices

Code of Ethics (p.91)

Monitoring of HR indicators (p.74)

Subcontractors

Code of Conduct (p.89)

Audit program (p.89)

Corrective action plans

Raw material suppliers

Responsible Purchasing Charter (p.87) Responsible Purchasing Charter (p.87)

EcoVadis evaluations (p.88)

To be defined

Transport companies

Latin America: Signing of the BIC Code of Conduct (p.71) U.S.: Smartway certifications (p.71)

To be defined

Other service providers

Responsible Purchasing Charter (p.87)

To be defined

To be defined

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BIC GROUP - 2017 REGISTRATION DOCUMENT