Plastic Omnium // 2021 Universal Registration Document

NON-FINANCIAL REPORTING DISCLOSURE The vigilance plan

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THE VIGILANCE PLAN

To address social, societal and environmental challenges, this mapping is supplemented by the materiality analysis, which ranks risks and opportunities based on the assessment of the various stakeholders. These risk definition tools take into account different levels of assessment. Risk mapping is carried out at two levels to obtain a realistic and relevant assessment for all business lines: at Group level: the annual review of the risk mapping makes it possible ● to identify all of the risks borne by the Group. Risks related to suppliers and subcontractors are incorporated into this analysis. The Group’s risk mapping is presented in section 2 “Main risk factors” of the URD on p. 51 and the non-financial challenges are presented in section 4 under "Non-financial challenges materiality matrix" on p. 142; at local level: ISO 14001, ISO 50001 and ISO 45001 certifications ● require the completion of a risk map for each certified site. These analyses make it possible to score the risks and identify the actions implemented locally to prevent and correct potential breaches. The risks identified relate to all environmental issues (consumption of raw materials, discharges and pollution, chemical products, waste and attention to biodiversity, etc.) and health and safety issues (accidents, occupational illnesses and psycho-social risks, etc.). Top Safety visits also provide an opportunity to raise risk situations so that prevention, mitigation or corrective action can be taken quickly. These analyses make it possible to adapt to local specificities. Plastic Omnium’s international presence highlights different realities and regulations. Discussions with management and local teams were key to provide an analysis of the relevant risks. The risks identified fall into the following categories: risks related to human rights and fundamental freedoms: these are ● dealt with in the Internal Audit standards, which ensures in particular that employees’ working hours are respected and that child labor is not used; risks related to climate change and environmental pollution: measuring ● its environmental footprint and carrying out life cycle analyses enables the Group to identify the businesses that are most exposed to regulations and the expectations of clients, end-users or the financial markets. These risks are addressed as part of the ACT FOR CLIMATE Program, which includes, among other things, the Top Planet program, eco-design actions and the development of clean mobility solutions;

Law no. 2017-399 of March 27, 2017 on the Duty of Vigilance of parent companies and ordering companies requires companies to develop, publish and implement appropriate measures to identify risks and the means to prevent breaches to: human rights and fundamental freedoms, ● the health and safety of people, ● the environment, ● that may result from the activities of the Group and its subsidiaries, and those of the suppliers or subcontractors with which it has an established commercial relationship. The purpose of this regulation is to: prevent serious incidents or breaches in the above areas throughout ● the Company value chain. justify the request of any person, justifying an interest to act, and to ● engage the responsibility of the author of any damage to repair it. This obligation is based on five measures: risk mapping (identification, analysis, prioritization); ● procedures for regularly assessing the situation of subsidiaries, ● suppliers or subcontractors; appropriate actions to mitigate risks or prevent serious breaches; ● a mechanism for alerting and collecting alerts relating to the existence ● or occurrence of risks; a system to monitor the measures implemented and assess their ● effectiveness. The Vigilance Plan is part of the Group’s strategy and its sustainable development program ACT FOR ALL TM which promotes ethical business and responsible purchasing. GOVERNANCE OF THE VIGILANCE PLAN The Purchasing, Sustainable Development, Legal and Human Resources Departments participate in the drafting, implementation and monitoring of this Vigilance Plan. Its progress is also monitored by the Executive Committee and during ACT FOR ALL TM Committees which meet two or three times a year. The measures concern subsidiaries and suppliers. In addition, from 2022, the Board of Directors is setting up an Appointments and Sustainable Development Committee composed of three members to focus on these issues. RISK MAPPING For subsidiaries The risk mapping analyzed as part of the Vigilance Plan is included in the Group risk mapping, which presents the main risks considered as material and specific to Plastic Omnium’s activity and business lines.

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PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2021