Plastic Omnium // 2021 Universal Registration Document

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

Performance In total, more than 2,750 suppliers went through the supplier risk assessment system in 2021, i.e. 1,250 additional suppliers compared to last year. The performance indicator, the Supplier Ethics Index, a marker for the ACT FOR ALL TM program, combines the deployment rate of three tools on a weighted basis (the database, the Suppliers’ Charter and the Sustainable Development assessment by an external third party). In 2021, reached 89.5%.

A diagnostic tool currently being implemented will make it possible to identify the suppliers most at risk, starting in 2022. This risk analysis will cover the bulk of Plastic Omnium suppliers, representing more than 95%. On January 1, 2021, a new legislation came into force in the European Union: the Conflict Minerals Regulation. Plastic Omnium is committed to promoting the ethical sourcing of all materials used in the manufacture of its products.

CONFLICT MINERALS

Policy The “conflict minerals” policy, implemented within Plastic Omnium, aims to facilitate the traceability of sources of conflict minerals used in the manufacture of products and thus avoid the supply of these minerals from countries in conflict (e.g. “concerned countries”). The so-called 3TG products targeted by this policy are as follows: Tin; ● Tungsten; ● Tantalum; ● Gold. ● These minerals are present, for example, in the coatings of metal components, certain paint pigments, electronic components and in painted or chromed plastic parts. Reporting The reporting, described in the Purchasing procedures, is based on the Conflict Minerals Reporting Template (CMRT) developed by the RMI (Responsible Minerals Initiative). This form makes it possible to verify that the foundries and refiners declared by the suppliers belong to the list of foundries listed by the RMI. Roles and responsibilities The Purchasing Department ensures that the required suppliers produce the information requested, forward it to the conflict minerals managers and take appropriate actions, where necessary. The conflict minerals manager is responsible for the following tasks: keeping abreast of current international laws and regulations and consolidating updates regarding countries, minerals and reporting obligations; ● reparing reporting with external suppliers; ● verifying supplier compliance; ● providing the CMRT report to OEM customers who request it. ●

HUMAN RIGHTS RISKS 4.3.2.5 Risk description

Policies and procedures Plastic Omnium supports the highest Human Rights standards in conducting its operations by belonging to globally recognized organizations and initiatives: United Nations Global Compact; ● United Nations Universal Declaration of Human Rights and its two ● complementary covenants; Fundamental Conventions of the International Labor Organization (ILO); ● ILO Declaration on Fundamental Principles and Rights at Work; ● OECD Guidelines; ● United Nations Sustainable Development Goals (SDGs). ●

Respect for Human Right is a prerequisite to any action at Plastic Omnium. Through its presence in 25 countries, the Group operates directly or indirectly with a large public. As an employer, the Group is responsible for ensuring that employees’ rights are respected (Human Resources risks addressed on p. 150). The Group also ensures that Human Rights are respected throughout its value chain: in its contractual and partnership relationships with its suppliers, subcontractors and within its subsidiaries (Responsible Purchasing risk and Vigilance Plan addressed on p. 177).

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PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2021

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