LEGRAND_REGISTRATION_DOCUMENT_2017

04

CORPORATE SOCIAL RESPONSIBILITY (CSR)

Limiting our environmental impact

Nevertheless, since 2004, Legrand has made it a goal to eliminate RoHS substances from all of its solutions, starting with those marketed in Europe, whether they are covered by the scope of application of the Directive or not. This includes Legrand products which are not considered asWEEE under the Directive. As a result, in 2007 the Group adopted lead-free welding processes, opted for the use of lead-free PVC from 2009 (mainly in the manufacture of cable management profiles), and gradually extended Cr(VI)-free passivation of surface coatings of metal parts. The Group is therefore already ready for the RoHS open scope scheduled for 2019. Furthermore, the Group has added to its CSR roadmap the target of complying with the RoHS Directive’s restrictions on the use of hazardous substances for its entire global offering by the end of 2018 (including those outside the scope of the RoHS Directive). At the end of 2017, 93% of sales were generated from products compliant with the regulatory restrictions on the use of substances defined by the RoHS Directive (against a target of 98%). The Group’s acquisitions policy affected performance, by merging with companies not subject to this regulation and marketing products potentially containing the substances in excess of the regulatory restrictions under the RoHS Directive. REACH Regulation Legrand takes into account the requirements of the European REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) Regulation 1907/2006 and takes all necessary measures to be in compliance. As a proactive player in this process, Legrand goes beyond regulatory requirements. For example, when developing its products, it has undertaken to exclude any substances included in the REACH “candidate list” whenever a technically and economically viable alternative is available. Legrand is therefore also involved in the application of the European REACH regulations, in particular by facilitating the transmission of data on the relevant substances used in its economic chain (upstream and downstream). This includes: W arranging the collection from strategic suppliers of Material Safety Data Sheets on substances and preparations, such sheets being key components of REACH for transmitting product information; W providing the Group’s European customer service departments with a response system connected to the Group’s intranet site covering all brands. This ensures transmission of the most up-to-date information; W posting a full page dedicated to REACH on the Legrand website for the use of all stakeholders. To bolster and maintain this proactive approach, a REACH expert committee, including the Group’s materials and processes experts,

is to raise awareness among participants of the constraints and opportunities of the WEEE recycling process. As a result, good design practices with a view to the dismantling of end-of-life products have been established at Legrand’s R&D centers. Finally, the Product Environmental Profiles (PEPs) developed by the Group (covering 67% of the Group’s total sales at the end of 2017 – see section 4.2.1.3 of this document) are information tools specifically designed for recycling centers (showing, for example, the potential for recycling and recovery and the location of sub- assemblies requiring specific treatment). They also facilitate the recovery of Legrand products at the end of their life. Use of recycled materials Legrand is committed to using recycled materials whenever possible. Contacts established with players in the recycling industry (particularly Récylum in France) have led to new opportunities being identified for the use of recycled post-consumer plastics (see examples given in the section on waste management). This practice is specifically recognized and promoted as part of the Legrand Way towards ecoconscious design , which frames the Group’s global ecodesign approach. Note that the use of recycled plastics generally raises technical issues and requires specific R&D work: in 2017, Legrand filed an ORPLAST application for the inclusion of a high percentage (up to 50%) of recycled polyolefins (post-consumer waste) in some of its cable management products. ORPLAST is a scheme run by the French environment and energy management agency (ADEME) to encourage the use of recycled plastics. The incorporation of recycledmaterial inmetals is amore common practice. For example, ordinary steels generally contain between 30% and 50% of recycled material. The technical constraints adopted by Legrand in its specifications do not specifically limit the use of steel from the electrical sector containing the highest levels of recycled steel. The same applies to aluminum and copper alloys, which the Group uses in large quantities and which in some regions may contain up to 50% and 80% respectively of recycled metal. R 4.5.2.2 TRACEABILITYAND DISPOSAL OF HAZARDOUS SUBSTANCES RoHS Directive The RoHS (Restriction of Hazardous Substances) Directive lays down rules restricting the use of hazardous substances for electrical and electronic products. Originally adopted in 2003 ahead of its implementation in 2006 it was revised in 2012 RoHS (2011/65/ UE), and the list of target substances was extended in 2015.

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REGISTRATION DOCUMENT 2017 - LEGRAND