2021 Universal Registration Document

RISKS MANAGEMENT

Vigilance Plan

Mitigation and remediation measures/Due diligence process Since 2019, BIC has a Group procurement organization to ● implement an integrated best practice approach worldwide. To this end, BIC Purchasing teams and Supply Chain teams have merged into a global department. One of its most important objectives is to implement the Vigilance Plan with respect to the supply chain (suppliers, subcontractors, transporters) continuously and consistently. Moreover, BIC has completed an audit of raw materials ● impacting 26 suppliers to identify and evaluate all supply risks for the Lighters category. Results were provided in Q1 2021 and a specific mitigation plan in this respect was established. The audit and related methodology have been expanded to the other categories in 2021. In addition, the Responsible Procurement 2025 Road Map ● aims to identify value creation levers on the supply chain and assess and mitigate any sustainable development risks. The execution plan provides for appropriate actions to be rolled out for each category and supplier type. In 2021, 52.6% of the strategic suppliers were integrated the program with at least one of the responsible procurement actions and the target is that 100% of the strategic suppliers will be part of the program by 2025. Furthermore, BIC has implemented in 2019 and throughout ● 2020 and 2021 a Responsible Procurement Training Program as a part of the BIC Capability Building Program. The Group’s Supplier Code of Conduct launched in 2020 is ● communicated to all BIC suppliers. In 2021, BIC developed and deployed a third party due ● diligence program to monitor, identify, mitigate and document any exposure to corruption and unfair practice risks. Such due diligence and mitigating actions is managed and documented through an integrity tool. The third party due diligence program is a 6 step risk based ● approach which categorizes & identifies suppliers, performs risk assessments, understands the risk, evaluates such risk, mitigates any risks and monitors and continuously reviews suppliers and notifies of any risks on an ongoing basis. The first phase of the program focused on BIC’s strategic ● suppliers and Contract Manufacturers. There are currently a total of 358 suppliers, representing 50 countries of which 25 countries are identified as high risk. Out of the 358 suppliers, 150 suppliers have been evaluated and approved as low risk/medium risk and remain continually monitored. The remaining suppliers are currently being evaluated.

In parallel, and conjunction with the above, BIC has updated ● the list of its strategic suppliers (323 as of the end of 2021) based on specific criteria. In 2021, BIC has continued enhancing mitigation and ● remediation measures such as incorporating into calls for tender or in the referencing process criteria on Environment and Health and Safety. Due diligence has been carried out periodically on such issues. In the event of major non-compliance, a dereferencing process is in place. Specific measures, as presented below, may apply. For more details on the approach of our responsibility in the value chain, the implemented measures, and the results, please refer to Section 3.5. Ethics and business conduct across the value chain. Regular assessment process BIC Procurement teams implement the following process to ensure the regular assessment of the risk’s mitigation measures: monitoring, screening, vetting and mitigating risks of the ● strategic and high risk suppliers; monitoring of the CSR criteria in the calls for tender or in the ● referencing processes; monitoring of the suppliers’ panel by the audits, document ● reviews, assessments, etc.; monitoring of the audit results, document reviews, ● assessments, etc.; Results – Key extra-financial performance indicator Key extra-financial performance indicators, such as the compliance rate of the suppliers with respect to the dedicated criteria in response to calls for tender and the implementation of external assessment of suppliers, were defined and will be implemented according to the different purchasing categories. C. The “BIC Speak-Up” hotline accessible to all BIC team members and third parties and allows any violation of the BIC Anti-corruption Policy and BIC Code of Conduct to be reported (see § 3.5.3 Business conduct and combatting corruption ) and thereby offers an alert mechanism to report on risks covered by the Law. The alert hotline is accessible on BIC internal and external websites. Alert hotline monitoring of the correction action asked for; ● monitoring of the dereferencing decisions. ●

60

• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •