technicolor - 2020 Universal Registration Document

DISCLOSURE ON EXTRA-FINANCIAL PERFORMANCE SAFETY OF CUSTOMERS AND PROTECTION OF CONTENT

SAFETY OF CUSTOMERS AND PROTECTION 5.6 OF CONTENT Product compliance and ban of hazardous materials 5.6.1 GRI [102-12] [102-13] [103-1 Procurement Practices] [103-2 Procurement Practices] [103-3 Procurement Practices] [103-1 Materials] [103-2 Materials] [103-3 Materials] [103-1 Environmental Compliance] [103-2 Environmental Compliance] [103-3 Environmental Compliance] [103-1 Supplier Environmental Assessment] [103-2 Supplier Environmental Assessment]

[103-3 Supplier Environmental Assessment] [103-1 Public policy] [103-2 Public policy] [103-3 Public policy] [103-1 Customer health and safety] [103-2 Customer health and safety] [103-3 Customer health and safety] [308-1] [308-2] [416-1] [417-1]

Manufacturers of electronic products face growing sustainability requirements and increasing regulations concerning eco-design and energy efficiency. The variety and proliferation of environmental regulations as well as norms, standards, frameworks, and customer standards influenced both by stakeholders and in-process regulations, has reinforced the need for better environmental management. Resource efficiency requirements are now set to become a reality for many products manufacturers supplying the EU market. The Group has put into place the necessary processes and initiatives to comply with law restricting the use of hazardous substances, such as, but not limited to, the European Restriction of Hazardous Substances (RoHS) directive and the Restriction, Evaluation and Authorization of Chemical substances (REACH) regulation. KEY PRODUCT ENVIRONMENTAL AND SAFETY REQUIREMENTS COMPLIANCE Technicolor operates in a worldwide market and thus has to deal with a wide variety of national and regional initiatives governing the environmental performance and risk management associated with its products. In particular, energy consumption, which is the main significant environmental impact for our products remains a key priority across the industry and regions. In Europe, therefore, Technicolor continues to support voluntary EU industry initiatives such as the Industry Voluntary Agreement (VA) for Complex Set-Top Box, and the Code of Conduct (CoC) for Broadband equipment. Technicolor has actively contributed to creation or revision of eco-design regulations impacting the design and development of Technicolor gateways and set-top box by providing inputs to the EU commission, via its membership of the Digital Europe organization of leading Digital Technology European companies. Especially with regard to eco-design requirements on the new regulation for no-load condition electric power consumption and average efficiency of External Power Supply 2019/1782 and regulation 801/2013/EU on standby and network standby. The scope of Technicolor contributions and monitoring are extended on non-energy related topics such as Reusability/Recyclability/Recoverability (RRR). Each eco-design regulation contains provisions for its future evaluation and possible revision, taking into account the experience gained with their implementation and technological progress. In the Americas, in Australia, in Asia, in Africa, and in the same manner, Technicolor monitors and follows environmental regulations and standards. In the United States for example, Technicolor follows the Department of Energy proposed amendment on external power

supplies and rulemaking initiatives on efficiency standards for Set-Top Box and Network Equipment. Currently, Technicolor is signatory of the U.S. Voluntary Agreement for the Ongoing Improvement to the Energy Efficiency of Small Network Equipment , and the U.S. Voluntary Agreement for the Ongoing Improvement to the Energy Efficiency of Set Top Box Equipment . In Canada, Technicolor is signatory of the Canadian Pay-TV Set-Top Box Energy Efficiency Voluntary Agreement (STB CEEVA), and the Canadian Energy-Efficiency Voluntary Agreement for Small Network Equipment (CEEVA SNE). In Australia, Technicolor is an Associate Member of the Subscription Television Industry Voluntary Code for improving the energy efficiency of conditional access Set-Top Box. Compliance methods and actions are in place with regard to the RoHS (Restriction on Hazardous Substances), and WEEE (Waste Electrical and Electronic Equipment) European directives, and the REACH (Registration, Evaluation, Authorization and Restriction of Chemicals) European regulation, or similar legislation in regions other than EU Member States, dealing with the Restriction on the use of Hazardous Substances within products and systems, and preparing for better end-of-life handling of Electrical and Electronic Equipment Waste. In 2021, in the context of the Waste Framework Directive, the European Chemicals Agency (ECHA) will establish the Substance of Concern in Products (SCIP) database, and companies that supply articles containing Substances of Very High Concern (SVHCs) will have to submit notification on these articles to the new EU SCIP database. In 2020, Technicolor Connected Home studied and developed a new program and processes to successfully support supply chain data communications required for compliance with the new EU REACH SCIP database (including but not limited to suppliers’ awareness and training, instructions and data collection templates). In 2010, the United States was one of the first countries to take the initiative to bring about legislation to combat the conflict minerals trade. Since 2014, companies in scope of U.S. Law were first required to check and report on the use of conflict minerals in their products. From 2021, the new Conflict Minerals Regulations (EU) 2017/821 creates supply chain due diligence obligations, which will begin to take effect for EU-based importers of 3T ores and concentrates, as well as gold above defined thresholds. As a RBA member, our approach is to rely on the Responsible Business Alliance (RBA), formerly Electronics Industry Citizenship Coalition, and Global e-Sustainability Initiative (GeSI) Conflict Minerals Due Diligence reporting template and dashboard as a standard questionnaire for conducting inquiries into our supplier database. The Responsible Minerals Initiative (RMI), formerly Conflict-Free Sourcing Initiative (CFSI), a combined initiative of RBA and GeSI, defined a common industry approach to support the due diligence information requirements. They developed a reporting template for downstream suppliers called the Conflict Mineral Reporting

5

TECHNICOLOR UNIVERSAL REGISTRATION DOCUMENT 2020 189