Plastic Omnium // 2021 Universal Registration Document

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NON-FINANCIAL REPORTING DISCLOSURE The risk management and non-financial reporting of the Group

whistleblowing mechanism: alerts from employees to report behavior 6. or situations which infringe the Code of Conduct are collected by e-mail (corporatesecretary.ethicsalert@plasticomnium.com), mail (Compagnie Plastic Omnium, Alerte Éthique, 1, allée Pierre Burelle, 92300 Levallois-Perret, France or other means), employees may also inform their managers or Human Resources of any breaches of the Code of Conduct, if they wish. Alerts are treated anonymously. The process is described in the Code of Conduct, available in 22 languages on the intranet and on the Group’s website. The procedures for handling alerts are the subject of an internal procedure for employees, available in 22 languages on the Group’s intranet. In order to handle with these alerts, they are all tracked in an internal dashboard. Alerts are recorded by type, reporting mechanism and monitoring. HBPO alerts are reported by the compliance officers. For Intelligent Exterior Systems and Clean Energy Systems, the principal reporting method is through line management, followed by the alert mechanism presented above. For these business lines (Excluding HBPO), new processing procedures were implemented in 2021: alerts are examined by an ad hoc committee composed of the Compliance, Human Resources and Internal Audit Departments. This committee studies the alerts, the need to call on an internal or external third party to investigate, decides on the response to the alert, monitors progress and/or closes the alert; disciplinary regime: at Plastic Omnium, the Code of Conduct has the 7. same legal effect as Internal Rules where the law allows. A zero tolerance policy has been introduced by the governing body: any breach of the rules of the Code of Conduct may expose employees to disciplinary sanctions. Where permitted by law, a reference to the Code of Conduct has also been added to employment contracts. From 2022, at the request of the Compliance Department, the Human Resources Department (through local Human Resources Departments) must report to the Compliance Department all disciplinary sanctions taken in the context of violations of the Code of Conduct; internal control mechanism and assessment of measures 8. implemented: the Internal Audit Department performs an annual audit of its entities and sites to ensure compliance with procedures and the efficiency of the processes to prevent, detect and correct wrongdoing. In 2021, 23 audits were conducted. TAX EVASION Due to its presence in 25 countries, Plastic Omnium is subject to a significant number of often complex tax regulations, the structure and interpretation of which are likely to generate risks. The Group has therefore defined a certain number of principles that govern its tax policy: compliance with the laws and regulations in force in the countries in ● which it operates, including the filing of tax returns and making the required payments on time; a commitment not to create subsidiaries in so-called "non-cooperative" ● countries or to use structures lacking economic substance in the event of the acquisition of such a structure as part of a M&A (Mergers & Acquisitions) transaction, Plastic Omnium would endeavor to liquidate it to the extent possible; the implementation and regular update of a transfer pricing policy in ● line with the arm’s length pricing principle; building constructive and professional relationships with tax authorities. ● Thus, Plastic Omnium has committed to the Tax Partnership with the French tax authorities;

In addition, Plastic Omnium’s membership of the United Nations Global Compact since 2003 requires it to comply with the 10 principles relating to respect for Human Rights and international standards on labor, environmental protection and the fight against corruption. The Internal Control and Compliance Committee is comprised of managers from Human Resources, Finance, Compliance, Risks, Internal Audit, Legal, and business lines Departments. It guides the Group’s policies and actions and relies on a network of Compliance correspondents around the world. Mechanisms to comply with the French law known as the Sapin 2 law (Law no. 2016-1691 of December 9, 2016 on transparency, the fight against corruption and the modernization of economic life) were put in place and implemented by the Group as follows: the Code of Conduct; 1. employee training and awareness: e-learning training continued 2. throughout 2021. Initially available in four languages (English, German, French and Spanish), the Code of Conduct e-learning module was translated into three additional languages (Slovak, Polish and Chinese) in 2021 to ensure coverage of countries where the number of employees identified as at risk is the highest. Whenever a new language is available, the employees concerned must follow the training in their own language. This e-learning is also mandatory for all new Group employees. In 2021, Plastic Omnium supplemented its “Compliance Days” training campaign, with the aim of training at-risk populations (Executive Committee, Finance, Human Resources, Quality, Sales, Buyers, etc.) in local languages in conjunction with local lawyers on three topics: competition, ● anti-corruption, ● conflicts of interest. ● From 2022, the Group will continue its regular training effort by varying the themes and countries at risk. A new anti-corruption e-learning module will be created to detect and prevent the risks of corruption and factual situations encountered by Plastic Omnium in all the countries in which the Group operates. This module will be available in all 22 languages as well as dialects specific to certain regions. In 2020, HBPO introduced its own e-learning module, incorporating training videos made available by the United Nations. A three-year plan provides for the gradual enhancement of e-learning as well as the training of all managers and administrative staff; corruption risk mapping: : the mapping was conducted in 2018 for 3. Clean Energy Systems and Intelligent Exterior Systems and in 2019 for HBPO. A review of the risk mapping is planned for 2022. procedures for evaluating third parties: when referencing third 4. parties, in addition to financial analyses, Plastic Omnium conducts CSR performance assessments with a particular focus on the risk of corruption. Third parties are also asked to sign up to the Group's Suppliers’ Charter and are subject to assessments and audits; internal or external accounting audit procedures: these are designed 5. to ensure that the books are not hiding corruption. These procedures are regularly audited by internal audit at subsidiary, site or administrative function level;

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PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2021