2021 Universal Registration Document

RISKS MANAGEMENT

Description and mitigation of main risk factors

Risks related to counterfeiting/Gray Goods, Parallel Imports and Non-compliant Products from competition Counterfeits of the most well-known BIC products circulate throughout Africa, the Middle East, Eastern Europe, and South America. They are mostly produced in Asia. These counterfeits, often of low quality, are mainly focused on our products’ shape and on the BIC ® trademark. Gray good products that violate U.S. regulations pose product recall risks. The Group is confronted with competition from low-cost lighters that often do not comply with safety standards, the ISO 9994 international safety standard, and the EN 13869 child resistance standard. Level of risk impact: medium Potential impact on BIC: Examples of Risk Mitigation: impact on the Brand image (Consumers) and business interests. •

the Legal Department fights against these counterfeits, gray goods, or • non-compliant products and works closely with local authorities and law enforcement agencies. Among the initiatives undertaken by the Legal team are: initiating court and administrative actions, • enforcing a monitoring program of leading e-commerce platforms, • market surveillance, traceability measures, and collaborating with • local authorities to better prevent illegal diverting of gray goods to the U.S. BIC also fights against non-compliant lighters through communication • activities, informing stakeholders (customers, market surveillance authorities, EU Commission, EU Parliament, etc.); in 2021, the Group intensely advocated its proposals to improve market • surveillance effectiveness in Europe. Part of the Group’s proposals was included in the EU Commission’s General Product Safety Regulation proposal (June 30, 2021); BIC worked to improve lighter safety standards in Mexico, advocated • maintaining strong market surveillance legislation for lighters in Brazil, and enhanced market surveillance campaigns in Argentina.

Risks related to increased regulations Restrictions, prohibitions, and prohibitions projects are more and more numerous in the fields of chemical substances and plastics, particularly in North America and Europe. Level of risk impact: medium Potential impact on BIC: Examples of Risk Mitigation: impact on manufacturing processes and business interests. • BIC closely monitors announced regulatory changes and voices relevant technical and legal arguments:

BIC is launching collection and recycling projects and making proposals • to improve the relevance of new laws and regulations, starting with the Balearic Islands and Valencian regions where collection and recycling of lighters and shavers are required; together with other European manufacturers, BIC continues to object • to the EU Commission’s interpretation of the EU’s CLP regulation scope. This regulation would require labeling each writing instrument and lighter, with warning phrases on the chemical substances in containers. It would also require Safety Data Sheets for each product. If BIC articles were considered as mere containers of mixtures, this could also trigger the application of laws relating to packaging and packaging waste; BIC is voicing its proposals as part of the ongoing revision of the EU’s • CLP regulation. BIC put a strong focus in 2021 on the management and mitigation of consequences of the EU’s new restriction of the titanium dioxide content, potentially affecting all coloring products.

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• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •