Plastic Omnium // 2021 Universal Registration Document

NON-FINANCIAL REPORTING DISCLOSURE The vigilance plan

PREVENTION AND MITIGATION ACTIONS For subsidiaries

WHISTLEBLOWING PROCEDURE Whistleblowing system

A number of policies and procedures govern the actions of the Group and its subsidiaries. The Code of Ethics is the first instrument governing the actions of the Company and its employees. It outlines the commitments undertaken in terms of respect of Human Rights, fundamental freedoms, health and safety and the environment. In order to prevent, reduce and correct impacts, policies and procedures have been defined and implemented by the dedicated departments at Group level (HSE and Sustainable Development Department, HR Department, Compliance Department, etc.): the Code of Conduct, the Code of Compliance with competition law, the ● “Fundamentals and Golden Rules of internal control” and the Charter for the use of communication resources and IT tools have legal scope. In the event of a breach, sanctions may be applied; the ACT FOR ALL™ program, the Top Planet and Top Safety policies: ● defined at Group level and deployed in all business lines, these policies govern desired behavior within Plastic Omnium; the commitment in 2003 to the 10 principles of the United Nations ● Global Compact; the inclusion of Sustainable Development criteria in the criteria for ● awarding the variable portion of compensation: in 2021, 100% of directors had a Sustainable Development objective in their individual performance plan. Local networks of correspondents are responsible for operationally applying the policies and procedures defined at Group level. For suppliers Since 2021, the assessment of a supplier has had certain consequences: a supplier whose risk is high will first of all be accompanied, in order to understand the reasons for its assessment and the possibility of rapid remediation. If its risk profile is confirmed, it will have to put in place an action plan that will be validated and monitored by Plastic Omnium. In the absence of an action and improvement plan, it may be excluded from the panel. Additional measures are also in place: the conditional requirement to certain contractors to be certified ● according to the ISO 14001, ISO 45001 standards; a major discrepancy identified, for example during an audit, that may ● lead the Group to take all necessary measures to guarantee its integrity and sustainability; training; ● the inclusion of contractual clauses on social and environmental issues ● in the General Supply Terms and Conditions in its supplier, subcontractor and service provider contracts. Two issues in particular are monitored by the Group: chemical products: products covered by the European REACH ● regulation must be registered. Plastic Omnium is working with an external service provider to ensure that products meet regulations and that the safety data sheets (which provide information on risks and stipulate usage precautions) are up to date. Because the lists of products covered by REACH change regularly, this work involves anticipating regulations; conflict minerals (see p. 164). ●

Since 2018, the whistleblowing system has been accessible to external third parties via the Group’s website. This system manages all alerts in the strictest confidentiality, so that whistleblowers can report any potential breaches without fear of retaliation, in accordance with local laws. In addition, the operating procedure exists in the Group’s 22 main languages and is available on the intranet. The procedures for system entry were also presented to the competent Employee Representative Bodies. Alert processing If direct management cannot intervene, employees are invited to use the two channels available to them: an email address: corporatesecretary.ethicsalert@plasticomnium.com; ● a mailing address: Compagnie Plastic Omnium, Alerte Éthique, 1, allée ● Pierre-Burelle, 92300 Levallois-Perret, France. The information is processed anonymously and sent to the Group Compliance Department. The triggering of an alert is treated confidentially to ensure the protection of whistleblowers. In 2021, nine alerts were received (two for HBPO and seven for Intelligent Exterior Systems and Clean Energy Systems). All alerts received were dealt with by the Group with, where necessary, an in-depth investigation, possible intervention by Human Resources and disciplinary measures. Whether they are internal or reported by third parties in connection with the Group’s activities within its value chain, alerts mainly concern issues related to ethics risks. MONITORING OF MEASURES IMPLEMENTED AND ASSESSMENT OF THEIR EFFECTIVENESS Extra-financial data is presented annually in this section and is monitored on a monthly, quarterly or annual basis using dedicated reporting tools to measure changes, improvements and any discrepancies to be corrected. These data concern, for example, work organization, overtime, compensation, incidents of discrimination, equal opportunities, health and safety as well as greenhouse gas emissions and energy consumption, consumption of raw materials, waste and environmental incidents. The issues covered in the ACT FOR ALL™ program are subject to specific monitoring within dedicated Committees. In addition, targets have been set for the ACT FOR ALL TM program’s 13 markers by 2025 with intermediate annual targets (See the ACT FOR ALL TM table on p. 138). The assessments carried out by third parties show a constant improvement in the Group’s non-financial performance (refer to the section entitled “Report from the Independent Third Party” on p. 193). In total, 2,750 suppliers went through the supplier risk assessment system in 2021, i.e. 1,250 additional suppliers integrated compared to last year. In addition, a diagnostic tool being implemented will make it possible to identify, from 2022, the suppliers most at risk. This risk analysis will cover all of Plastic Omnium’s suppliers, representing more than 95%.

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PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2021