SAINT_GOBAIN_REGISTRATION_DOCUMENT_2017

4

An efficient and responsible Group Reference policies

REFERENCE POLICIES 1. The compliance culture 1.1

The compliance culture that drives the Group is developed through its values, formalized in 2003 in the Principles of Conduct and Action (see Chapter 1, Section 2.1). This compliance culture has been supported by a full program since 2009 which strengthens the effective application of the Principles of Conduct and Action and the resulting obligations, in all the Group’s Activities and worldwide. Compliance is an ongoing obligation that applies to all employees. As regularly noted by the Group’s General Management, the principle of zero tolerance is observed. At all hierarchical levels, it becomes obvious for committed managers. Teams in charge at all Group levels The compliance program is monitored by the Board of Directors of Compagnie de Saint-Gobain. Its implementation is based on a compliance network, coordinated by the General Secretary and composed of more than 100 functional operating managers who are members of Compliance Committees within the Group and the General Delegations. the Group’s Compliance committee is composed of the „ Chief Operating Officer, the Corporate Secretary, the four Senior Vice Presidents in charge of the Sectors, the Senior Vice President in charge of Internal Audit and Internal Control, the Chief Financial Officer and the Chief Compliance Officer. The committee meets twice a year and monitors the follow-up on completed actions, validates the subjects to reinforce and the action plans to come. 35 Compliance Correspondents operate both in countries „ and in Sectors in order to disseminate the policy of implementation of the programs, to manage the operational teams and to control and report results. In particular, they are trusted to answer operational questions and to advise their teams. Compliance committees are set up in each of the 14 „ General Delegations in the same way that for the Group’s committee. At operational level, the dissemination of the compliance culture and values is supported by: the General Management, which engages in the „ communication and reminders of compliance rules, both internally and externally; the Responsible Development Department, which „ promotes the Principles of Conduct and Action among all employees; the Compliance Department within the Legal Department, „ which draws up and implements the programs associated

with specific themes such as conflicts of interest, the Embargo policy or the action plans relative to the professional associations policy; the managers, who are trained regularly and who are „ responsible to endorse and implement them; the Internal Audit and Control Department (see Chapter 7, „ Section 2), which verifies the effective application thereof. A comprehensive set of tools that deploy the compliance program Regularly enriched since its launch, the compliance program is today focused on the following main subjects: compliance with the rules on anti-trust law: as part of the „ Competition Law Plan established in 2009, various actions are implemented, such as training measures (online and in-person), conduction of audits, provision of practical guides and newsletters but also of dedicated teams for all operational questions on the subject; prevention of corruption: a program of measures and „ good practices is managed and implemented in the Group’s subsidiaries in order to prevent the risk specifically connected with international commercial transactions, passive and active corruption in relations with public officials and the private sector. It is composed of training tools (online and in-person), internal policies (gifts, conflicts of interest, intermediaries, HR, etc.) and is monitored by the compliance network; compliance with economic sanctions and with embargos „ for which screening tools, training (online and in-person) and specific policies are applied. An active monitoring of changes is also carried out in close association with specialist external lawyers. This results in a well-established and well-structured compliance culture. Supported by the Group’s General Management and passed on to all levels by the managers and the compliance network, it is constantly developing based on topical subjects. Various tools are used to implement the Group’s compliance program: a dedicated Intranet, known as “Compliance”, where key „ messages are passed on and tools are made available to all Group employees; several e-learning modules, that must be undertaken by all „ managers, and various on-site trainings are provided by the Corporate Secretary, the Vice President of Competition and Legal Affairs, the Vice President of Responsible Development and the Compliance Correspondents.

64 SAINT-GOBAIN - REGISTRATION DOCUMENT 2017