BIC_REGISTRATION_DOCUMENT_2017

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY Responsibility concerning our products

organizations and industry associations,  (1) actively participates in regulatory watch and interactions with local regulatory authorities, an important activity for staying abreast of new requirements. Marketing compliant products that are safe for human health and the environment To guarantee consumer safety, the BIC Group category Directors 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 Leadership Team and management teams are systematically kept abreast of new developments in product safety and regulations. Systematic testing and evaluation programs Before they arrive on the market, all BIC® products, including modified products, must pass a full program of safety qualification tests. 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 Group 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 the Commission’s 2006 decision on 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. The procedure remains pending.

COMPLIANCE WITH THE REACH REGULATION D

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, initial registration has been completed for the substances that needed it, and the teams involved have begun the procedures for registering the remaining substances before the final deadline in 2018. Progress made in 2017 ♦ In 2017, training operations were organized for production managers and technicians regarding the evolution of regulations and the resulting adaptations of the Group’s processes. Clarifying the purpose of these adaptations, the sessions were conceived to help BIC operatives in their implementation. A total of 32 managers (in charge of operations, technical supervision, products, quality, purchasing and R&D, project managers and factory Directors) at the Samer, Boulogne and Conté factories in France benefited from this training. Training sessions focusing on the inventories of chemical substance in various countries (REACH in Europe, TSCA in the U.S., NICNAS in Australia, etc.) were continued in 2017. Lastly, more than 314 products were tested in independent laboratories. Perspectives ♦ In the coming years, the Group will continue to adapt its working methods and means to maintain its own standards and level of compliance concerning product safety. BIC will continue to expand its regulatory watch activities to remain ready to adapt its processes, products and formulas as needed. The Group also plans to continue developing and extending its product safety training.

In particular, the BIC Group is a member of EWIMA (European Writing Instrument Manufacturers Association), WIMA (Writing Instrument (1) Manufacturers Association), ACMI (Art & Creative Materials Institute), TIE (Toy Industries of Europe), EFLM (European Federation of Lighter Manufacturers), and the Fédération des Entreprises de la Beauté in France.

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BIC GROUP - 2017 REGISTRATION DOCUMENT

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