SAINT_GOBAIN_REGISTRATION_DOCUMENT_2017

Additional information and cross-reference tables CSR information

CSR INFORMATION 2.

Duty of vigilance plan 2.1 Saint-Gobain’s vigilance plan is established with respect to the French law n°2017-399 of 27 March, 2017 on the duty of vigilance of parent and subcontracting companies. It is constituted of two plans that are both distinct and complementary: the vigilance plan for the Activities of the Group (holding „ company, subsidiaries, joint-ventures and on-site subcontractors); the vigilance plan relative to Purchases, including tier 1 „ suppliers and external subcontractors. These two plans are based on the application of Saint-Gobain’s ethical code of conduct, the Principles of Conduct and Action, and on Group-level policies that most often apply to several stakeholders, thus integrating the Group’s activities and its value chain. Depending on the cases, procedures for policy implementation are disseminated in particular: risk assessment procedure for human rights; „ the Frame of Reference for the Environment, industrial „ Hygiene, Health and Safety management system (EHS). The implementation modalities of the Responsible Purchasing policy for trade and non-trade purchases are integrated into the policy’s annex. The vigilance plan relative to the 2.1.1 Group’s Activities Risks linked to human rights a) The implementation procedure of the “human rights” policy adopts the methodology of risk identification of real or potential negative impacts. This method is based on the United Nations’ recommendations, in particular those relative to the guiding principles on business and human rights. The mapping of risks tackles the nature of risks linked to both the activities and the countries in which Saint-Gobain is present. The identification of risks linked to the activities was carried out internally according to the methods put forward by the Danish Institute. The selected salient risks are: Forced labor; „ Child labor; „

Freedom of association; „ The use of recruitment agencies; „ Discrimination. „

The identification method for risks linked to countries is coordinated with that of the Responsible Purchasing program. Following the Group’s organization, countries at risk are grouped by General Delegation. This way, Saint-Gobain has identified 6 General Delegations that are concerned over their entire perimeter: Sub-Saharan Africa; „ Middle-East; „ Central America, Venezuela, Colombia, Ecuador and Peru; „ Asia-Pacific; „ Russia, Ukraine and CIS countries; „ India, Sri Lanka and Bangladesh. „ Three General Delegations are only concerned for specific countries: Mediterranean: Morocco and Algeria ; „ Poland, Bulgaria, Romania and Turkey: Turkey; „ Czech Republic, Slovakia, Hungary and Eastern Adriatic „ countries: Albania. A preliminary questionnaire relative to risk assessment and the identification of risk management programs has been addressed to the General Delegations concerned. Depending on the residual risks, action plans specific to each General Delegation or country will be established. These action plans will specify the measures for specific risk management and their efficiency. Human rights incidents are reported in Chapter 5, Section 2.4. Risks linked to the environment, the health and b) safety of employees The EHS Reference Frame is applicable to all of Saint-Gobain’s sites. It specifies the EHS management system to put in place and explains the risk identification and management method for environmental, health and safety risks posed to employees and on-site subcontractors. It is coordinated with the ISO 14001 and OHSAS 18001 requirements.

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