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An efficient and responsible Group Reference policies

An evaluation questionnaire, inspired by the Human Rights monitoring points may relate to employment practices, the Compliance Assessment (HRCA) of the Danish Institute for impact on local communities or management of the logistics Human Rights, has been developed and is supplemented by a chain.

direct questioning of the General Delegations or the Activities concerned for specific risks identified. These particular

Depending on residual risks, action plans will specify supplementary measures for risk management.

Environmental, Health and Safety policy 1.3 The Environmental, Health and Safety (EHS) policy was defined by the Chairman and CEO of Saint-Gobain in a commitment letter of undertaking updated in 2017. It is an extension of the code of ethical conduct: the Group’s Principles of Conduct and Action. It places the environment, health and safety on the same level of requirement and establishes the following as long-term objectives: zero work-related accidents, zero occupational illnesses, zero environmental accidents and minimum impact of the Group’s activities on the environment. These objectives are recalled in the Group’s EHS Charter, available in 30 languages and displayed on all sites.

Sectors, General Delegations and sites, reproducing the Saint-Gobain matrix organization coordinated by a central management. Saint-Gobain EHS Management draws up and circulates framework policies that have to be implemented by the Sectors and General Delegations, worldwide. These policies are supplemented by Saint-Gobain “standards” and “recommendations”, which are technical documents that describe the minimum requirements that the sites have to observe whatever the country and the local legislation. The themes for the policies, standards and recommendations are identified based on the recurrence or severity of the risks identified by the sites. The EHS Guidelines include assessment and oversight of the policy. The matrix of EHS risks and risk controls is also included in the internal control guidelines (see Chapter 7, Section 2.2.4). Audits on compliance of the EHS management system are conducted by the EHS Department and external certification measures complete the system for oversight of EHS policy. This way in 2017, 52 audits “12 steps” and 121 audits “20 steps” were carried out to evaluate industrial activities and 121 audits specific to the distribution activities were realized. In 2018, the EHS Reference Frame will be updated according to the new international norm ISO 14001: 2015 and the future ISO 45001. A new version of the internal EHS audit consistent with the new EHS Reference Frame will be launched. When an acquisition is made, the process of integrating the new entity into the Group includes a specific procedure for EHS policy implementation. Lastly, the EHS training matrix, which defines the training to be provided based on the job held, is a particularly relevant tool to define employees’ EHS training paths. A skills matrix is also available. The availability of adapted training, in the local language, falls under the responsibility of the General Delegations.

To support policy implementation, the EHS Guidelines available to the sites cover all EHS management system requirements as well as risk identification, action plans to be implemented, and monitoring and evaluation in order to ensure compliance and performance. It describes the approach for identifying and managing environmental risks as well as risks relating to the health and safety of employees and on-site subcontractors. In particular, the Guidelines describe the EHS management system that is to be implemented and set out a methodology for identifying, reducing and controlling risks that meet the requirements of the ISO 14001 and OHSAS 18001 international norms. Alongside the Guidelines, a health and safety risk assessment standard has been developed and circulated in 2014. A self-assessment questionnaire allows the tracking of its effective implementation. As a result, each site defines an EHS mapping and action plan under the responsibility of the Director of the relevant site. The EHS Guidelines are based on the principle of continuous improvement. At all sites where the World Class Manufacturing program for operational excellence is in place (see Chapter 4, Section 2.1), the EHS policy is incorporated by the site into the “environment and risk prevention” and “health and safety” pillars. Implementation of the EHS policy is based on a network of correspondents distributed throughout the Group within the

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