technicolor - 2020 Universal Registration Document

5 DISCLOSURE ON EXTRA-FINANCIAL PERFORMANCE HUMAN RIGHTS AND WORKING CONDITIONS

Beyond raw material and component purchasing, the main areas where Technicolor subcontracts production and services are the manufacturing of Set-Top Box and gateways of the Connected Home segment, and part of the logistics of the DVD Services Division in Europe. In addition, to manage seasonal peak workloads within DVD Services, Technicolor uses contracted labor services to provide additional workforce on packaging and distribution sites. To ensure that suppliers respect established principles, and as part of Technicolor’s Supplier Responsibility program, since 2003, Technicolor sourcing management: determines when CSR audits, always performed by Technicolor • selected auditors, are required; requires all suppliers to sign the General Rules of Conduct • Compliance Certificate; periodically reviews all suppliers according to the Technicolor • Suppliers Responsibility program requirements. The Technicolor Supplier Responsibility program: ensures that Technicolor suppliers respect our policies and program • requirements; promotes economic and social welfare through the improvement of • living standards and support for non-discriminatory employment practices. Technicolor actively seeks suppliers with similar interests and ethics commitments.

processes and products. During the audit process, instances of child labor are classified as “critical,” resulting in an immediate stoppage of business. Audits revealing employee discrimination, forced labor, safety violations, permanent disabilities or fatal injuries are classified as “major,” and require immediate corrective action. No critical violation was detected during 2020. 56% of detected violations relate to health and safety, and 33% to working hours. Health and safety violations represent 82% of major violations, while the remaining categories of major violations detected were labor and management system by decreasing order. Technicolor added a more systematic risk assessment of suppliers in 2018 with the implementation of the EcoVadis assessment platform (EcoVadis Rating Framework) for suppliers representing a yearly spending of more than €1 million. In 2020, such category represents 91.2% of the total spending of the Group. Suppliers representing about 80.9% of total spend of this category of Technicolor’s suppliers are already assessed by EcoVadis. The primary sub-contracting scope within the Group is within the Connected Home business, where sub-contracting represents the majority of units sold, and thus almost all audits originating as part of the Supplier Responsibility program are targeting suppliers and sub-contractors for the Connected Home business as sub-contracting is very low profile in Production Services and DVD Services. Conversely, the year-end seasonal labor peaks are strongly represented in DVD Services, and the Group ensures that all temporary workers receive all required EH&S training, information, and equipment for their responsibilities, no matter how limited the duration of employment, so that they are treated the same as any other worker within the Group. Technicolor monitors key performance indicators according to CSR criteria for key active electronics manufacturing service partners to ensure they comply with Corporate Social Responsibility regulations and practices. Technicolor Sourcing gives preference to suppliers who have achieved ISO 9001 certification and who are certified to meet such EH&S standards such as ISO 14001 and ISO 45001. Additionally, the Responsible Business Alliance (RBA) may perform on-site audits to monitor and verify the implementation of the RBA Code of Conduct. Mindful of regulations banning or restricting certain chemical substances, Technicolor implemented a process for obtaining and tracking information about its suppliers. This system allows for the identification and estimation of relevant chemical substances in Technicolor’s products and ensures that banned substances are not included. In 2016, Technicolor’s commitment was confirmed by a Technicolor public statement on Conflict Minerals available on www.technicolor.com, along with other Technicolor statements on compliance with UK and California anti-human trafficking laws.

Suppliers are expected to adhere to these basic principles: tolerate no discrimination and encourage diversity; • promote best working conditions; • use no child labor or forced labor or involuntary labor; • protect worker health and safety; • respect the environment; •

support worker development; • respect fair market competition; •

strive to be a good corporate citizen wherever Technicolor operates; • prevent and avoid all forms of bribery, corruption, or other unfair and • unlawful action;

respect consumer and personal privacy; • avoid potential conflicts of interests. •

33 on-site Supplier Responsibility audits were performed in 2020 by Technicolor, either on-site or remotely, concerning 32 sites as one site was audited two times. Through these audits and other methods, Technicolor shares its expectations that suppliers and their subcontractors provide safe and healthy working conditions for their employees, abide by human rights laws and standards, and strive for continual improvement in their environmental management systems,

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