LEGRAND / 2018 Registration document

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CORPORATE SOCIAL RESPONSIBILITY AND DECLARATION OF EXTRA-FINANCIAL PERFORMANCE

ACTING ETHICALLY TOWARDS SOCIETY

Management of hazardous substances Questions relating to hazardous substances and the ecodesign capability of suppliers are covered in the supplier approval phase. The Registration, Evaluation, Authorization and restriction of Chemicals Regulation (or REACH Regulation) and Directive 2002/95/ EC on the Restriction of Hazardous Substances (or the RoHS Directive) are specifically mentioned during the supplier evaluation operational stages referred to above; suppliers must, for example, disclose whether the substances regulated by the RoHS Directive are present in the products that they supply to the Group. Suppliers of rawmaterials, particularly plastics, are also encouraged to send their Material Safety Data Sheets (MSDSs) to Legrand. A panel of experts from the central materials laboratory works with designers and buyers to identify the types of materials and items purchased with a high probability of containing REACH substances. The aim is to prioritize the constructive consultation of the suppliers concerned. To comply with this regulation, a REACH process has been put in place. Conflict minerals In a number of countries around the world but especially in the Democratic Republic of Congo and neighboring countries, the extraction and trade of certain minerals funds armed groups, conflicts and crimes against the population. The main minerals concerned, known as “conflict minerals”, are cassiterite (tin ore), coltan (tantalum ore), wolframite (tungsten ore) and gold. Given the nature of its business, Legrand is never in a position where it has to purchase directly any minerals in their primary form, so these minerals have little impact on it. However, as a responsible player, Legrand supports OECD initiatives by following the guidance contained in the “OECD Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas”, and is developing a strategy to identify and assess the risks associated with its supply chain. It has also carried out a risk analysis to identify the suppliers involved. This position was confirmed in November 2015 with the publication of Legrand’s Conflict Minerals Policy, signed by the Group Procurement Director. The Group is conscious of the amount of information to be processed, but has undertaken to question the relevant suppliers. At the same time, Legrand is endeavoring to respond to customer demands in this respect. As a downstream company, Legrand therefore works with its most exposed suppliers to ensure that the metals used originate from sources that are free from conflict minerals. To date, the investigations carried out have confirmed that conflict-free sources are used. However, if Legrand were to identify a supplier that uses metals derived from conflict minerals, the Group would immediately take the necessary action to address this.

W on-site audit results: no serious discrepancies were detected during the audits. The action plans mainly highlight the need to produce periodically the necessary documentary information (environmental certificates, for example) and to formalize health and safety procedures (for example, hazard warning notices in factories, reminders to wear safety masks, gloves and footwear, preparation of an evacuation plan and associated drills, better chemicals storage, etc.); W since 2015, five cases have resulted in a plan to withdraw and remove a supplier from the Group’s list of suppliers. Focus: Legrand acknowledged for the support it provides to higher-risk suppliers in terms of CSR In March 2018, the Legrand Group was awarded the bronze medal in the CSR category of the “Trophées Décisions Achats” purchasing awards. This event, which takes place every year in Paris, is intended to highlight outstanding initiatives and players in the world of purchasing, while facilitating discussion between professionals. Legrand’s 2014-2018 CSR roadmap led to the creation, across more than 25 countries, of a community of trained purchasers, supported by environmental and health and safety specialists applying a common methodology to assess and help suppliers exposed to CSR risks to achieve progress “in the field”. The 2019-2021 CSR roadmap will follow on from those efforts, with improved detection of exposed suppliers via the CSR risk mapping method that the Group adopted with the support of Ecovadis in January 2019. Involving and training buyers Parties involved in supplier relations, buyers, quality controllers, designers and experts apply the principles of the CSR strategy through purchasing procedures. One of the commitments of the purchasing policy is skills development for all stakeholders within the purchasing function. The induction module for new buyers includes a specific section on CSR with, in particular, an introduction to the code of ethics and procedures. In 2018, 10 new buyers and people on work/study programs received training. Since 2015, under the CSR roadmap, people in 25 countries have been trained in the methodology for detecting and monitoring higher-risk suppliers in terms of CSR and in the management of the corresponding action plans. Of those 25 countries, training was provided in three in 2018, and mainly in Southeast Asian entities. The other 22 countries where training had previously been provided continued to roll out their training programs and other actions. In total, around 120 people across the Group have received training in the management of higher-risk suppliers in CSR terms. In addition, buyers take part in specific themes, such as the Science Based Targets initiative (SBTi) (see section 4.5.1.3). To continue the involvement of Legrand employees in responsible purchasing efforts, one of the priorities of the 2019-2021 roadmap addresses this theme (see section 4.3.2.2).

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REGISTRATION DOCUMENT 2018