Plastic Omnium // 2021 Universal Registration Document

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NON-FINANCIAL REPORTING DISCLOSURE The vigilance plan

For suppliers In 2021, for listed suppliers, the assessment system includes three tools: A database incorporating the financial information plus the 1. Sustainable Development data: the database is enriched each year. For suppliers who are part of a group, Plastic Omnium collects data from the parent companies; The Suppliers’ Charter: when referenced, Plastic Omnium requires 2. each supplier to sign the Group’s Suppliers’ Charter, available on the Internet. Equivalence with their own charters, if comparable, is accepted. Deployed since 2016, the charter is built around the following references: the United Nations’ Universal Declaration of Human Rights and its • two additional covenants (the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights); the ten principles of the United Nations Global Compact; • the Fundamental Conventions of the ILO (International Labor • Organization) and the ILO Declaration on fundamental labor principles and rights; the OECD Guidelines. • The suppliers undertake to comply with: competition law; • laws and regulations aiming to fight corruption and money • laundering; human rights and working conditions: prohibition of the use of • forced or compulsory labor in all its forms, the use of child labor, prohibition of discrimination in terms of employment and working conditions and guarantee of equal pay and freedom of association and protection of the right to organize. Finally, they are committed to maintaining a safe and healthy work environment. In the event of a breach, Plastic Omnium may require the supplier to take corrective measures or terminate all or part of the contract for negligent non-performance. A CSR assessment by an external third party: Plastic Omnium has 3. chosen EcoVadis as a partner to assess its supply chain. From 2022, the suppliers who are required to prepare an EcoVadis assessment file will be identified on the basis of the results of the systematic diagnostic mentioned above. When combined, the three assessment tools allow Plastic Omnium to assess its suppliers according to three levels of risk: low, moderate or high. Since 2021, depending on its level of risk, a supplier may fail to be selected for certain Group projects. Thus, a supplier that presents a high risk must put in place an action plan validated by Plastic Omnium in order to be able to join or remain in the panel. A supplier that has not signed the charter cannot join the panel. An additional control is carried out through the ISO 14001, ISO 45001 (or OHSAS 18001) and ISO 50001 certifications of the sites. They compare the suppliers’ level of compliance with internal requirements. In 2021, 2,750 suppliers went through the supplier risk assessment system, i.e. 1,250 suppliers more than last year. The performance indicator, the Supplier Ethics Index, a marker for the ACT FOR ALL TM program, combines the deployment rate of the three tools on a weighted basis (the database, the Suppliers’ Charter and the Sustainable Development assessment by an external third party). In 2021, it was 89%.

health and safety risks: social climate surveys and monitoring by HSE ● teams make it possible to draw attention to working conditions, psychosocial and health and safety risks. These risks, as well as the mitigation measures that accompany them and the monitoring indicators are described in the Statement of NFRD. For suppliers A diagnostic tool being currently 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’s suppliers, representing more than 95% of its purchasing volume, while including all suppliers in certain sectors targeted by the risk mapping: intermediaries, and service providers acting on behalf of Plastic Omnium, such as customs brokers, are considered particularly exposed. Supplier risk analysis is based on the following five risk factors: country, sector of activity, inclusion on international sanctions lists, the existence of politically exposed persons in management bodies or the shareholding structure and published controversies. New suppliers are referenced on the basis of certain criteria, requiring different degrees of investigation, in the areas of quality, financial robustness and Sustainable Development performance. Until now, supplier risk was considered a moderate risk for the Group, with financial health and ethics as the main point of attention. In 2021, a “material/component shortage” risk was added, due to the shortage of semiconductors, which had a major impact on customers and indirectly on the production. In addition, the measures taken due to the health crisis to guarantee the health and safety of populations have amplified certain risks with two types of impact: image impact: Plastic Omnium’s reputation may be affected by ● behavior that does not respect human rights regarding health and safety measures throughout the value chain; operational impact: a failure in the manufacturing chain can disrupt supply. ● ASSESSMENT MEASURES For subsidiaries Several processes are in place to assess the performance of subsidiaries in different areas. Indicators are regularly monitored via the Group’s non-financial reporting tool dedicated to monitoring social and environmental indicators. The main results are presented at meetings of Executive Committees and ACT FOR ALL TM Committees. These results are used to set the main guidelines and targets, to define policies and to analyze deployment and any gaps. The main results are also presented twice a year to the European Works Council. In addition, the Internal Audit Department plans an annual program of control visits to subsidiaries and sites. At the beginning of 2021, the audits continued remotely with the help of a local auditor and then resumed in person in the middle of the year. 22 audits were carried out. In addition to the traditional topics of an internal audit, quality, health/safety, environment and certain human rights aspects are also addressed.

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PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2021