2021 Universal Registration Document

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

Our products [NFPS]

a global approach, resulting in products that often exceed the ● safety requirements of local markets; expecting BIC suppliers to comply with safety standards; ● incorporating safety considerations right from product design, ● including toxicological evaluations and tests to assess potential physical and chemical hazards; the anticipation of product safety requirements through active ● regulatory monitoring at national and international levels. This is done in close cooperation with industry associations that share their members’ expertise with the appropriate authorities; the incorporation of innovations into product safety processes; ● building awareness among all stakeholders about safety and ● the appropriate use of BIC ® products; carefully reviewing all incidents involving the safety of BIC ® ● products;

appropriate measures for product recall or withdrawal in the ● case of an incident; the implementation of this Policy by a Product Safety ● Department. [NFPS ‒ the well-being of animals] In its position on animal testing, BIC specifies that it strives systematically not to resort to animal testing as a first solution. However, such tests can be necessary if: the alternatives do not provide sufficient guarantees that a ● new product is harmless for consumers; alternatives to animal testing are not recognized by regulation. ● In Brazil, the NBR 15236 testing standard was updated to allow alternatives to animal testing such as in vitro testing. In 2021, a toxicological evaluation of BIC’s finished products in accordance with the InMetro certification required for school supplies was conducted by Duke University in the United States. This evaluation allowed BIC to reaffirm its global position on animal testing and to not resort to animal testing as a first solution.

BIC’S SEVEN COMMITMENTS TO ENSURE THE QUALITY AND SAFETY OF ITS LIGHTERS

All BIC ® lighter plants are ISO 9001 certified production plants. BIC ® lighter products meet or exceed the ISO 9994 1. international safety standard requirements. BIC is an active member of various organizations (such as the European Federation of Lighter Manufacturers, working 2. groups and technical committees for ISO and CEN and numerous other national standardization bodies). This allows it to provide the latest and most reliable quality and safety information to its customers. Each BIC ® lighter undergoes over 50 separate automatic quality checks. Additionally, BIC conducts regular 3. post-market product tests of its lighters. BIC continuously develops and improves exclusive technology to ensure the quality and safety of all BIC ® lighters, 4. including factors like flame height and stability, extinction time, and a reservoir that can resist extreme drop tests and exposure to elevated temperatures. BIC has an integrated production process. It designs and develops much of its own machinery and uses all the latest 5. manufacturing technologies, from basic materials right down to the packaged lighter. BIC employees are all guided by three principles: Method-Precision-Discipline. Each employee in the lighter plants 6. spends close to 25% of his or her time checking product conformity and proper operation of the control equipment. BIC has been committed to sustainable, long-term safety programs for over 30 years. 7.

Regulatory monitoring and compliance BIC has a comprehensive monitoring system based on formalized regulatory monitoring process. This comes on top of internal and external resources and in particular the Product Safety teams’ specific knowledge of BIC ® products, their components and the materials used. In 2018, a BICWatch List was created to extend the Group’s monitoring system to include unofficial lists used by NGOs, future regulations and controversial substances that are not yet banned.

The Group always strives to anticipate the substitution of regulated substances. This Watch list is by its very nature open-ended. Since 2019, the Watch List has been factored into product ratings in EMA. The Product Safety team works closely with the product design teams to stay abreast of changes to the list and ensure its incorporation into product improvement. BIC, as a member of numerous industry bodies (1) , actively participates in regulatory monitoring. This is important to stay abreast and take into consideration new requirements.

In particular, BIC is a member of: EWIMA (European Writing Instrument Manufacturers Association); WIMA (Writing Instrument Manufacturers (1) Association); ACMI (Art & Creative Materials Institute); TIE (Toy Industries of Europe); EFLM (European Federation of Lighter Manufacturers); and Fédération des Entreprises de la Beauté in France.

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• BIC GROUP - 2021 UNIVERSAL REGISTRATION DOCUMENT •