2021 Universal Registration Document

RISKS MANAGEMENT

Vigilance Plan

2.3.4

ORGANIZATION ANDMEASURES FOR THE PREVENTIONOF MAJOR

NON-FINANCIAL RISKS

Conduct (issued in 2020), the Global Procurement Policy (issued in 2020) the Responsible Purchasing Charter (incorporated in the Supplier Code of Conduct issued in 2020). These documents are listed in part 3.8.1. A presentation on the implementation of the new BIC Group Code of Conduct was made at the Audit Committee Within the scope of the Law, the major risks listed below correspond to the most critical risks identified (resulting from the probability of occurrence and the significance of the potential impacts regarding the applicable risks). held in February 2021.

The tables below refer to the pages of Chapter 3 of the Universal Registration Document which gives a detailed presentation of the issues, the policies, the initiatives, the accomplishments of the past year and the extra-financial performance of BIC. management. Those that address the topics covered by Law and provide the basis for BIC’s Vigilance Plan are: BIC Anti-Corruption Policy (updated in October 2020), the new BIC Group Code of Conduct (issued in 2020 and which regroups the former Code of Ethics and Code of Conduct), Health, Safety, Environment Policy (EH&S), the BIC Charter of Diversity, The Supplier Code of BIC has implemented a body of documents to facilitate risk

A.

Major risks arising from BIC Group activities [NFPS]

Mitigation and remediation measures/ Due diligence and regular assessment processes/Results – Key extra-financial performance indicators See the eco-design process in § 3.2 . Our products.

Major risks

Type of risks

BIC Policies

BIC Organization

Plastics: plastic waste and resource depletion

Environmental risk

2025 Commitment: #1 Fostering sustainable Innovation in BIC ® products

Implementation by the Categories, by the Purchasing Department, with the support of the Sustainable Development Department Implementation by the Sustainable Development Department EH&S Officer in each factory Implementation by the Product Safety Department Implementation by HR and each category EH&S Officer in the factories Implementation by HR for teammembers Implementation by each Factory Director Implementation by an Anti-Corruption Officer, the Legal Department, the Purchasing Department

Climate change

Environmental risks

2025 Commitment: #2 Acting against climate change

See the process of fight against climate change in § 3.7. Climate-Related Performance Report.

Product safety and Consumer Health and Safety Health and Safety of Teammembers

Risks for people health and safety

BIC policies for product safety

See the product safety policy in § 3.2.4 Product safety .

Risks for people health and safety

2025 Commitment: #3 Committing to a safe work environment. EH&S Policy BIC Code of Conduct, HR Policies

See the process of safety in the workplace in § 3.4.3 Health/Safety and well-being in the workplace .

See the measures for the respect of Human Rights in the workplace in § 3.5.2 Ensuring respect for human rights in the workplace .

Non-respect of Human Rights and Fundamental Freedoms (child labor, ILO conventions)

Risks on Human Rights and Fundamental Freedoms

Unfair practices (Corruption)

Risks of active or passive corruption

BIC Code of Conduct and BIC Anti-Corruption Policy

See the anti-corruption fight process in § 3.5.3 Business conduct and combatting corruption .

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• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •