BIC_REGISTRATION_DOCUMENT_2017

OUR ENVIRONMENTAL, SOCIAL, AND SOCIETAL RESPONSIBILITY Our societal responsibility

Ethics and the fight against 2.5.1.3. corruption Challenges ♦ BIC generates 36% of its sales in countries where the risk of corruption is considered high or very high (Brazil, Mexico, India, Italy and Argentina) and 62% in countries with a medium or low risk of corruption according to Transparency International, including France, the United States and Spain. Approach ♦ Compliance with ethical principles and the fight against all forms of corruption, active or passive, are stipulated among the standards of the BIC Group Code of Ethics and BIC Group Anti-Corruption Policy. Since 2007, the BIC Group Code of Ethics has defined the fundamental ethical principles that the Group asks all of its employees to follow under all circumstances and everywhere in the world. The objective is to build and sustain an authentic corporate culture of integrity, honesty and fairness. The Code of Ethics comprises: 14 standards covering the following aspects: respect for ● fundamental Human Rights, respect for the environment, compliance with the law, listening and communicating, and the prevention of any form of active or passive corruption; 13 principles governing the behavior of BIC employees to control ● risks arising from conflicts of interest, the protection of the Group’s assets, professional commitments, and relationships with its stakeholders; a Guide listing the questions that all BIC employees must ask ● themselves to assess their level of compliance with the Code of Ethics and facilitate its understanding and implementation. The Code of Ethics, as approved by the Board of Directors and the CEO, and its guide are available in 15 languages. The text of the Code is available to all employees on the Group Intranet. Since 2016, the BIC Group Anti-Corruption Policy has defined the appropriate conduct mandatory for all BIC personnel, including employees, Directors and administrators, and for all parties acting on the Group’s behalf: subsidiaries, affiliate companies, partners under contract, wholesalers, consultants… The Policy describes how business must be conducted with third parties to protect against corrupt practices and avoid their occurrence. BIC Group does not tolerate any kind of corruption or bribery and has made a commitment to fight corruption in all of its forms. The Anti-Corruption Policy covers the following topics: interactions with government officials, private entities and ● persons who are not government officials; gifts, corporate gifts and sponsorship; ● relations with stakeholders; ● donations, contributions to communities and political parties; ● conflicts of interest; ● monitoring, record keeping and reporting of any breaches of ● anti-corruption laws. Progress made in 2017 ♦ Due to the complex nature of the various local and international anti-corruption/anti-bribery laws, BIC conducted a global compliance risk assessment in 2017 to identify, quantify and mitigate potential relevant risks to the business. Conducted by an

independent Auditor, this global risk assessment focused on anti-bribery and corruption to understand employee perceptions, attitudes and behaviors that affect the operating environment, and to assess key organizational compliance initiatives. In parallel with this risk assessment, BIC began bolstering its global anti-corruption compliance program by updating its Code of Ethics and conducting training on the Code of Ethics and mandatory training on the Anti-Corruption Policy, in-person for all managers globally and via e-learning for all employees in North America, Europe and Latin America. The Group has also launched an anonymous and confidential reporting system called “BIC Speak Up,” accessible by telephone and internet to all current and former BIC employees 24 hours a day and available in more than 200 languages. A small number of reports were raised in 2017. Anti-harassment training has also been made available to employees in the U.S. and Latin America. In the coming years further training will be extended to cover additional aspects of compliance. Perspectives ♦ The Group plans to extend its e-learning training programs to Asia Pacific and Cello. An evaluation of the risks related to third parties is also planned, and the Group will continue to review and strengthen its Anti-Corruption and Ethics program every year. Approach ♦ BIC Group participates directly and indirectly in the local economy in every region where it has operations. Every time it starts operations in a new region, BIC’s policy is to favor local hiring over expatriation. As a result, the Group has a total of only 87 expatriated employees today (1.09% of permanent employees). BIC thus contributes directly to local economies by generating jobs. Historically located in Europe, BIC has been developing and maintaining industrial jobs in this region, in particular in France, Spain and Greece, for several decades. The Group promotes “Made in France” and “Made in Europe” products in its catalogs, thus contributing to the creation of value and jobs in these countries, which have been especially hard hit by the economic crisis that began in 2008. BIC values the local manufacturing of its products so that it contributes to local economic development and includes the local communities in the value chain. The Group has strongly localized its manufacturing operations, especially via a network of six licensed factories solely for the Middle East-Africa zone. This local partnership approach has brought BIC® products closer to its consumers, making them more affordable and minimizing transportation costs. There are multiple benefits for the partners and the communities alike, especially in local job creation, technology sharing and transfers, and enhanced product competitiveness. SUPPORTING THE LOCAL ECONOMY AND PROMOTING SOLIDARITY 2.5.2. Generating and maintaining jobs 2.5.2.1.

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BIC GROUP - 2017 REGISTRATION DOCUMENT