BIC : Responses to Written Question EN

Société BIC Annual General meeting - May 29, 2024 Responses to written questions

Translated by BIC

Questions from FIR (Forum pour l'Investissement Responsable) (1): April 8, 2024

1. To date, you still operate in Russia according to the KSE Institute1 and Yale University2. How many people does BIC currently employ in Russia?

We would also like to know, at the time you took the decision to remain in the Russian Federation's territory, how did you ascertain that your activities complied with your own human rights commitments and did not undermine the rights of your employees or other stakeholders?

What steps have you taken to ensure that you can identify human rights risks associated with your activities in Russia and those associated with the Russian-Ukrainian conflict, as well as the human rights impacts of your activities on people and the conflict?

In September 2022, the Duma passed a federal law (no. 31-FZ), whose article 9 stipulates that foreign companies operating in Russia participate in the mobilization. What process have you implemented to control participation in the war effort? In case of mobilization, how does this comply with your ethical and human rights commitments? In this context, how do you ensure that your company does not violate international humanitarian law and become complicit in potential war crimes committed by the Russian army in Ukraine?

The Group remains attentive to geopolitical tensions and armed conflicts and strives to limit their impact on its employees and activities worldwide. BIC gives fundamental importance to the respect of human rights and ensures that the rights of each employee are respected in their respective countries. The federal law in Russia has not affected any of our employees at the moment, however we continue to monitor the situation closely to reassess, if necessary, potential consequences for our employees.

As mentioned in our 2023 Universal Registration Document, BIC has no manufacturing facilities in Russia and Ukraine. In 2023, Russia and Ukraine accounted for less than 3% of total net sales.

BIC has less than a hundred employees in Russia, does not manufacture any products in Russia and does not buy any raw materials there.

BIC retains full control of its brand and intellectual property in Russia, to counter any attempt to appropriate its brand.

We are also complying with European and American policies of sanctions against Russia, implementing any new decisions and ensuring the protection of our employees in the country. In addition to complying with sanctions, since the beginning of the Russian-Ukrainian conflict, BIC has restricted its offer on the Russian market to essential shaving and writing products, as well as lighters, and has suspended all its advertising activities in the country, as well as its investments, acknowledging the resulting competitive disadvantage this can result it, compared to certain international competitors.

1. Has your governance in terms of human rights and human rights risk management in conflict-affected or high-risk areas changed since the beginning of the invasion of Ukraine by Russia in February 2022? What lessons have you learned from this conflict, and how has it influenced the way you manage these situations?
   Long before the conflict in Russia, we implemented a Group-wide human rights due diligence policy for our suppliers, applicable in every Group country.

Specifically in Russia, we have put in place a crisis management process involving the Executive Committee to assess the potential risks of our activities, particularly in terms of human rights.

We maintain weekly monitoring with the local management team, particularly regarding the support of the physical and mental health, and economic situation of our employees.

1. In the event of a new conflict involving one of your areas of operation around the world, how do you ensure that human rights risks are taken into consideration in the decision to maintain your operations or not? According to what governance process: consultation with the Board of Directors, senior management, trade unions, exchanges with investors, engagement with local populations and local non-governmental

organizations? How do you involve human rights teams in these decisions?

We keep a close eye on every new conflict situation around the world and have done so since BIC was founded in 1944. We are present in around 160 countries and adapt our local activities to each situation. This long experience enables us to act with flexibility and efficiency when new conflicts emerge around the world. Our employees in Russia and in other conflict zones receive our full attention in terms of respect for human rights.

4. What is now your policy on developing new activities in high-risk areas (2)? Have you implemented a reinforced due diligence policy for these areas?

Our geographical coverage is already very dense, BIC being present in around 160 countries around the world. In addition, as mentioned earlier, we monitor the situation on a case-by-case basis for every new conflict. In this case, we have taken restrictive measures concerning our business in Russia.

1. https://leave-russia.org/societe-bic
2. https://som.yale.edu/story/2022/over-1000-companies-have-curtailed-operations-russia-some-remai

1. FIR is a French multi-stakeholder association founded in 2001 to promote and develop SRI (Socially Responsible Investing). FIR brings together all SRI players: investors, management companies, brokers, extra-financial rating agencies, investor advisors, trade unions, NGOs, as well as academics, lawyers...

Every fall, FIR organizes the Responsible Finance Week. In 2010, FIR launched CorDial, a platform for dialogue with listed companies on sustainable development issues. Every year since 2005, FIR has awarded prizes and scholarships to the best European research projects in "Finance and Sustainable Development". Since 2010, this prize has been organized in partnership with the UN Principles for Responsible Investment (UNPRI).

Together with the AFG - Association Française de Gestion Financière - and the Eurosif, FIR is one of the sponsors of the Transparency Code for open funds. This code must be adopted by all SRI funds in France. FIR is a member of the French CSR Platform and one of the founding members of Eurosif.

1. According to Step 2 of the OECD Due Diligence Guide, a high-risk area is "an area of political instability, repression, institutional weakness, insecurity, collapse of civil infrastructures, widespread violence, widespread human rights violations and abuses, and violations of national and international law".