SAINT_GOBAIN_REGISTRATION_DOCUMENT_2017

An efficient and responsible Group Reference policies

internal policies that are disseminated throughout the „ organization by the Compliance network; internal audits, based on compliance questionnaires that „ are filled out each year by all the entities, and external audits, carried out by specialized lawyers; a compliance alerts system, allowing employees to report „ any non-compliance with the applicable laws, the Group’s internal rules and procedures and the Principles of Conduct and Action. All reports are examined and, if necessary, investigated. When they are found to be justified, appropriate measures are taken. Supporting the compliance culture within the Group involves calling upon many participants both centrally and locally. To that end, the Group regularly organizes events in order to mobilize its employees. In 2017, the Group held its first World Compliance Day, when: Respect for Human rights 1.2 The first two principles of the Global Compact, which Saint-Gobain joined in 2003 (see Chapter 1, Section 2.2.1), invite businesses to “promote and respect the protection of internationally proclaimed human rights within their sphere of influence” (principle 1) and to “make sure that their own companies are not complicit in human rights abuses” (principle 2). In 2008, Pierre-André de Chalendar, Chairman and CEO of Saint-Gobain, signed the statement of support for human rights by company leaders on the occasion of the 60 th anniversary of the Universal Declaration of Human Rights. Saint-Gobain’s values, formalized by the Principles of Conduct and Action, are an essential means of mobilization for human rights owing to their reference to international conventions, particularly the International Charter for Human Rights and the applicable conventions of the International Labor Organization. More specifically, the Principles of Conduct and Action (Respect for employees’ rights) state that “the Group Companies […] must refrain from any form of recourse to forced labor, to compulsory labor or to child labor, either directly or indirectly or through subcontractors when the latter are working on a Group site”, such concepts having to be taken within the meaning of the applicable Conventions of the International Labor Organization. “They shall not apply any discrimination whatsoever vis-à-vis their employees, on recruitment, during execution or on termination of their contract of employment”. The Group companies shall verify the age of their employees by performing additional verifications, as needed, in cooperation with the local authority. Similarly, for child labor, the Group companies shall ensure that they are not involved in forced or compulsory labor in

a video address from the Group Chairman and Chief „ Executive Officer and the Corporate Secretary entitled “Compliance, a matter of performance for Saint-Gobain” was broadcasted to all employees throughout the world; each of the Group’s Sectors and General Delegations got „ involved and organized events to illustrate compliance in operation and engage employees through fun activities relating to their working day (exhibitions of Saint-Gobain products that could have a dual use, interactive games, various quizzes, video competitions, etc.) a practical guide on anti-corruption measures was „ translated into several languages and disseminated (Act for your Business). Finally, the Group has also strengthened its partnership with charity Transparency International. For every Group employee who completes at least one episode of the optional section of the “Act” training course, the “Business Act Game”, Saint-Gobain donates €1 to Transparency International. any way, particularly through dialog with the personnel representation entities, in an effort to detect any violations. Since 2014, the Group has increased the collection of information on discrimination. The systems for collecting complaints have been improved to favor the expression of employees' concerns. The clarification of internal definitions has made it possible to facilitate the handling and monitoring of information. Companies now declare any incidents of discrimination leading to a complaint or otherwise, in the course of judgment or finally judged and characterized as such. Every incident declared is examined and dealt with in the companies concerned. Specific reporting has been introduced to measure the results of the actions undertaken to promote the respect for fundamental human rights and to demonstrate to operational managers the Group’s determination to ensure that its fundamental values are applied and respected. This measure is extended to Saint-Gobain suppliers by the observance of its Responsible Purchasing policy. This policy specifically incorporates respect for human rights such as the fight against forced labor and child labor. The specific measures taken by the Group to ensure this are set out in Chapter 4, Section 2.2. Within the scope of its due diligence on human rights, the Group strives to identify and manage the potential risks connected with its activities by integrating its supply chain. Consequently, the Group has implemented a procedure for detecting specific risks based on the countries that it interacts with; either directly by its activities or by the presence of its suppliers. The risk assessments incorporate the Group’s perception and that of the relevant stakeholders. This procedure is based on the United Nations’ recommendations, in particular the guiding principles on business and human rights.

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