2021 Universal Registration Document

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

Ethics and business conduct across the value chain [NFPS]

combatting unfair competition; and ● environmental protection. ●

stationery: ●

toy safety; •

BIC lobbies primarily as a member of various organizations, participating as needed in their working groups and the development of their positions: French, European and American professional federations; ● standardization committees for toys, lighters and writing ● instruments; French watchdog groups and intra-sector associations. ● BIC is a member of the Executive Committees of the main industry associations, and in some cases, has been for many years. Lobbying activities can also take the form of direct contacts with relevant authorities, institutions, governmental agencies and NGOs. The Group’s subsidiaries also cultivate direct relations with the national authorities in their countries of operation. However, the Group has no professional lobbyists on its payroll. In 2021, in addition to regulatory developments in the area of the circular economy and recycling, BIC has maintained its focus on monitoring ongoing regulatory and standardization issues concerning: all products: ● EU directives and regulations (review), • REACH, • CLP, • e-commerce, DSA; •

lighters: ● lighter standards and market watch. •

3.5.4.2

Clearly identified lobbying

responsibilities At the highest level within the Group, CEO Gonzalve Bich and the members of the Executive Committee are responsible for steering and monitoring all lobbying activities on a regular basis. The operational responsibility for BIC’s relationships with public authorities and institutions is delegated to a small number of named managers to represent the Group in the above-mentioned proceedings. The members of the Executive Committee are kept informed of progress of laws and regulations that affect their operations. BIC ensures strict compliance with local laws and regulations in the pursuit of its lobbying activities. Like all the Group’s activities, lobbying is governed by the Anti-Corruption Policy and the BIC Code of Conduct, which names the people to be notified in case of breaches. 3.5.4.3 The latest developments concerning lighters are shared with the Group’s team members at results presentations. The General Managers and Marketing Managers are also kept directly abreast of BIC’s lobbying efforts on lighters. Teammember awareness

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• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •

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