2021 Universal Registration Document

NON-FINANCIAL PERFORMANCE STATEMENT: OUR ENVIRONMENTAL, SOCIAL AND SOCIETAL RESPONSIBILITY

Ethics and business conduct across the value chain [NFPS]

3.5.2.2

BIC’s human rights in the workplace

The Supplier Code of Conduct See Section 3.5.1.1.

policy [NFPS] Limiting contract manufacturing

The social audit program [NFPS] Compliance with the Supplier Code of Conduct (see below) is verified by an audit program covering all the factories where BIC ® products are manufactured. BIC has had a specific audit program in place for over 15 years to ensure compliance with the Supplier Code of Conduct. The program applies to global contract manufacturers. It also applies to local contract manufacturers producing BIC ® products for local markets for BIC Consumer Products and BIC Graphic (Advertising and Promotional Products). Regular audits are conducted every two years to verify that standards are kept at a satisfactory level. Audits are carried out by third party Auditors. In 2014, BIC introduced the Workplace Condition Assessment (WCA) platform. This assessment tool is based on national laws, incorporating ILO standards and existing best practice. It is consistent with the Supplier Code of Conduct. The WCA comprises over 180 evaluation criteria covering a range of topics: child labor; ● forced labor; ● discrimination; ● harassment; ● freedom of association; ● working hours; ● salaries; ● employment contracts; ● health and safety; ● environmental responsibility. ● Contract manufacturers are audited and rated on each criterion and then given an overall score. This platform allows the Group to closely monitor a contract manufacturer’s performance for each indicator. Deficiencies in each evaluation criterion are rated as major, moderate or minor, thereby allowing the implementation of targeted corrective action plans. It also includes global benchmarks for each country and each Group business sector. All contract manufacturers producing BIC ® products are audited over a two-year cycle, during which improvement programs will be implemented based on deficiencies identified during the assessment. BIC sees social responsibility as a partnership that requires shared values. In this spirit, BIC favors a common commitment to improvement rather than breaking off relations with a partner. The box below explains the main steps in the evaluation of contract manufacturers.

BIC’s uses little contract manufacturing. Overall, 91% of the Group’s net sales are generated by products made in its own factories. 65% (1) of these factories are located in countries with no Human Rights risk according to Freedom House. BIC works with subcontractors primarily for Stationery products in the Consumer business and for Advertising and Promotional Products. Subcontracting gives the Group greater flexibility.

PERMANENTWORKFORCE BY CATEGORY OF COUNTRY IN RELATION TOHUMAN RIGHTS RISK (2) IN 2021 – BIC

1% Not free countries

42% Partly free countries

57% Free countries

CONTRACT MANUFACTURERS BY CATEGORY OF COUNTRY IN RELATION TOHUMAN RIGHTS RISK (2) IN 2021 – BIC

8% Partly free countries

37% Free countries

55% Not Free countries

Change in Freedom House score for India. This country was scored free in 2020. (1) Source: Freedom House. Change in Freedom House score for India. This country was scored free in 2020. (2)

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• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •