LEGRAND_REGISTRATION_DOCUMENT_2017

CORPORATE SOCIAL RESPONSIBILITY (CSR)

Acting ethically towards Society

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. By the end of 2017, the relevant Group suppliers had all been consulted. Three quarters of them disclosed their commitments regarding conflict minerals, while the remainder are still being analyzed. Depending on the complexity of the supplier’s upstream supply chain, the information received ranged from the supplier’s policy on Conflict Minerals to a duly completed CFSI CMRT template. Legrand is aware of the difficulty and complexity in obtaining this information, but is committed to pursuing this approach in the interests of disclosure and transparency. In addition, the Legrand North and Central America subsidiary (LNCA) is committed to respecting the ‘Due Diligence Guidance for Responsible Supply Chains of Minerals from Conflict-Affected and High-Risk Areas’ and the applicable requirements of section 1502 of the Dodd-Frank Act, which seeks to prevent the use of minerals that directly or indirectly finance armed groups in the Democratic Republic of Congo or in neighboring countries (“Conflict Minerals”). As a consequence, LNCA requires its suppliers to pledge to be, or become, “conflict free” (which means that this type of supplier does not source minerals from conflict zones) and to use only guaranteed “conflict free” foundries wherever possible. LNCA requires each supplier to issue comprehensive statements based on the EICC-GeSI format by highlighting the commitment of the supplier concerned to become “conflict free” and to learn about the country of origin of the tin, tantalum, tungsten and gold that it purchases. For more information on responsible purchasing within the Group, see the section on our website www.legrand.com .

under the CSR roadmap, 22 countries have been trained in the methodology for detecting and monitoring suppliers at risk in terms of CSR and in the management of the corresponding action plans. Of these 22 countries, 12 were trained in 2017 (mainly the Group’s entities in Europe, as well as in Egypt, Saudi Arabia, South Korea, Australia, Mexico and Chile), involving 29 people. The other 10 previously involved countries continued to roll out their training programs and other actions. In total, around 120 people across the Group are trained in the management of suppliers with CSR risks. At the end of 2017, the U.S. purchasing team, which coordinates the monitoring of suppliers with CSR risks within its area of responsibility, organized a training session on CSR audits with an external third party. The CSR audit was presented and explained to 30 people. A Mexican supplier also took part in the training, before a test was carried out on site for implementation purposes. The purchasing and quality teams, thus trained, will apply this methodology in 2018, fully in line with the Group methodology. 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; and suppliers must, for example, disclose whether the substances identified in the RoHS Directive are present in the products that they supply to the Group. Suppliers of raw materials, particularly plastics, are also encouraged to send their Material Safety Data Sheets (MSDSs) to Legrand. A panel of experts from the central materials laboratory has joined the 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. U.S. focus: Training teams in CSR audits with a view to deployment in 2018

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REGISTRATION DOCUMENT 2017 - LEGRAND