LEGRAND_REGISTRATION_DOCUMENT_2017

CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

at this stage mainly resided with suppliers using chemicals (for example, subcontracting surface treatment) and suppliers based in countries exposed to CSR risks (particularly social risks) and economically dependent on Legrand. The suppliers identified are referred to as “higher-risk suppliers” and are systematically managed within the following risk management system: W documentary audit: this takes the form of a detailed questionnaire containing around 20 questions on employee health and safety (including the assessment of occupational risks, the identification of personal and collective protective equipment and their use by employees), the management of environmental issues (e.g. effluent treatment), and finally the respect for human rights and fundamental freedoms (including respect for the eight fundamental conventions of the ILO). Documentary evidence must be provided to substantiate the answers given. A scoring system has also been developed to prioritize the CSR audits to be carried out on site. W on-site audit: this is carried out following the documentary audit on the basis of the score achieved. To consolidate its CSR audit methodology, Legrand prefers the CSR audit to be conducted jointly by the buyer and QSE expert, following amodel questionnaire prepared by the Group. Each country arranges its own CSR audits with local buyers and QSE experts, providing the sustainable purchasing manager with the audit schedule. Some countries, such as Brazil and Colombia, have updated their audit questionnaire in line with Group documents. In order to benchmark its CSR audit, Legrand worked with Bureau Veritas in 2017 and applied the SMETA social audit methodology (see, below, in the results of the 2017 CSR roadmap). W formal action plan: this is drawn up and sent to the supplier in question if one ormore deviations fromLegrand’s standards are identified. It requires suppliers to implement the improvement plan to meet the Group’s standards. This is largely a case of maintaining the relationship with the supplier concerned, but as part of a progress and monitoring program devised by the stakeholders concerned (buyers, internal customers, QSE experts, etc.). In extreme cases, particularly where a supplier has not sought to make any improvements, it may be phased out of the supplier portfolio. The progress of the action plan is monitored in the centralized Group Purchasing database. Legrand sought to make this a priority in its own right in the CSR roadmap for the period 2014-2018. Accordingly, each year it publishes the number of suppliers under review and the progress of the action plans as detailed below in the results of the CSR roadmap.

conduct joint supplier audits on site. This approach has already become established in most of the countries involved in the support process for higher-risk suppliers, such as Turkey, India, Colombia, Brazil and the Group’s European entities. This practice is in line with the 2015 version of ISO 14001 on the duty of care, which legitimizes such actions under the extended enterprise. W centralized monitoring: in 2017, this supplier CSR risk management system became a purchasing quality system procedure. To monitor its implementation, each step of this procedure has been defined as follows: documentary audit - 25%; on-site audit - 50%; monitoring the progress of the action plan - between 50 and 75%; risk removed when the action plan is 100% complete. The monitoring of higher-risk suppliers is thus centralized in a common database under the supervision of the Group’s sustainable purchasing manager. W reporting: the progress of the action plans and critical situations is reviewed quarterly by the Purchasing Management Committee and CSR Purchasing Steering Committee. From 2018, critical human rights situations will be reviewed by the Human Rights Committee (for more details, please refer to section 4.4.1, Respecting human rights, of this Registration Document). Focus: Application of the law on the duty of care of parent companies and principal contractors Legrand has fully taken into account this law and refers to the priorities of the CSR roadmap, which voluntarily prepared in advance for the provisions that subsequently became mandatory under the law of March 27, 2017. Since 2014 Legrand has published a vigilance plan not only for its own sites but also for its value chain, on the themes of human rights and fundamental freedoms, health and safety, and the environment. The vigilance plan covers all the statutory provisions, namely: W Risk mapping: please refer to the Group risk mapping defined in section 3.6 of this document, which focuses on human rights, health and safety, and environmental risks; W Procedures for the regular evaluation of subsidiaries: the Group’s procedures are detailed in sections 4.4.1 “Respecting human rights”, 4.4.2 “Guaranteeing occupational health and safety”, and 4.5 “Limiting our environmental impact”; W Procedures for regular evaluation of subcontractors and suppliers: the Group’s procedures are detailed in section 4.3.2 “Ensuring responsible purchasing”; W Whistleblowing mechanism: the whistleblowing mechanism is described in section 4.3.1 “Acting ethically”. As a reminder, the generic email address is: ethics.legrand@legrandelectric.com. It can be consulted on the Group’s website;

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Focus: CSR supplier audits – Legrand’s preference for the buyer/QSE expert partnership

To ensure that the themes of the CSR audit are firmly anchored in its practices, Legrand prefers the buyer and QSE expert to

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REGISTRATION DOCUMENT 2017 - LEGRAND