2021 Universal Registration Document

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

Ethics and business conduct across the value chain [NFPS]

THE SIX STEPS FOR EVALUATING CONTRACT MANUFACTURERS

The BIC contract manufacturer signs the BIC Supplier Code of Conduct. 1. An independent external monitoring agency conducts an initial assessment of the contract manufacturer. 2. BIC presents a corrective action plan (CAP) to the contract manufacturer. 3. The contract manufacturer implements the CAP within an agreed upon, reasonable time frame. 4. The Auditor conducts follow-up assessment(s) to confirm implementation of the CAP. 5. Ongoing assessments are conducted every two years. 6.

In 2021, 30 contract manufacturers (Consumer Products or BIC Graphic) were audited, representing 47% of active contract manufacturers.

3.5.3

BUSINESS CONDUCT AND

guidance on where employees can find relevant policies, ● procedures and guidelines. Regardless of their role, seniority or location, all team members are required, at all times, to comply with this Code, the Group’s policies and standards. The same is true of all applicable laws, regulations and industry standards that relate to their individual work. The BIC Code of Conduct covers the following topics: protecting the integrity of BIC and strengthening its ● reputation: conflicts of interest, gifts and entertainment, bribery and corruption, relations with governments and political bodies, brand protection, competition, money laundering, trade controls; valuing and respecting employees: health and safety, ● discrimination and harassment, Human Rights; protecting data, assets and information: IT security, ● company property and resources, data privacy and personal information, business records; maintaining high quality relationships and partnerships ● with all stakeholders: quality, environment, charitable contributions, external communications and social media, relationships with customers, suppliers and other business partners. The Code of Conduct is distributed to all new employees as part of the onboarding process. It is translated into seven languages – English, Spanish, French, Greek, Hindi, Portuguese and Russian – and is available on the BIC Intranet, the central information hub for all teammembers worldwide, as well as the website www.bic.com. Training sessions on the Code of Conduct are launched with periodic cadence on a repetitive basis in line with regulatory guidance. All employees are invited to attend these training sessions to ensure a complete and comprehensive understanding of the Code Additionally, an abridged version of the BIC Code of Conduct training was procured and launched for employees in the manufacturing plants globally. There are also micro-learning campaigns throughout the year to remind employees of the principles of the Code Business Conduct and such principles are well embedded in the BIC culture.

COMBATTING CORRUPTION [NFPS]

BIC strongly believes that in order to succeed as a business, the Company must uphold the strongest standards and principles at all times – acting responsibly, with the planet, society and future generations in mind. Over the years, BIC has formalized its values and ethical business practices. Integrity, Responsibility, Teamwork, Simplicity, Sustainability and lngenuity guide BIC’s actions, with the goal of building and maintaining relationships with all stakeholders – team members, customers, suppliers, Shareholders and regulators – in a way that fosters a culture of business integrity and ensures the highest standards of conduct globally. 3.5.3.1 [NFPS risk 6] BIC has identified risks related to corruption among its main CSR risks. The risk of corruption and unfair practices can lead to legal actions against the Group and major consequences in terms of reputation and attractiveness. Managing this risk is an opportunity for BIC to further develop its culture of ethics within the Group. Risks [NFPS] The BIC Code of Conduct BIC continuously monitors compliance and ensures team members are updated on the BIC Code of Conduct through training and awareness campaigns on the following: expectations as to how BIC’s business is conducted; ● the Group’s Vision, Mission and Values; ● proper behavior toward internal and external stakeholders; ● precepts on integrity that focus on the Values being applied in ● the workplace; and laws Policy, actions taken, results 3.5.3.2 and outlook [NFPS]

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