Plastic Omnium - 2018 Registration Document

3 STATEMENT OF NON-FINANCIAL PERFORMANCE CSR integrated in the business lines www.plasticomnium.com PLASTIC OMNIUM 2018 REGISTRATION DOCUMENT 96 This same year, Plastic Omnium developed its Code of Ethics and, since then, has consistently applied it. It has steadily evolved to support the Group's growth and development, and to implement an ethical approach across all entities, proving the Company's commitment to act responsibly in all countries in which it operates. The adoption in France of law no. 2016-1691 of December 9, 2016 on transparency, preventing corruption and on the modernization of economic life (known as the Sapin 2 law) requires Plastic Omnium to confirm and supplement this ethical approach, by implementing measures to prevent and detect corruption and influence-peddling in France and overseas. The newly developed and strengthened measures include: a Code of Conduct; ● a whistleblowing procedure; ● risk mapping; ● evaluation of the situation of clients, first-line suppliers and ● intermediaries as part of the risk mapping procedure; auditing of accounts, internally or externally; ● a training procedure; ● a disciplinary procedure; ● a procedure to internally check and evaluate the measures ● implemented. The Plastic Omnium Executive Committee, which began a rigorous systems-compliance process, has fine-tuned existing tools to align them with the recommendations of the French Anticorrupton Authority (Agence Française Anticorruption). This process, introduced by three members of the Executive Committee, will be completed in 2019. All of the information below was submitted to the Compagnie Plastic Omnium Board of Directors. Code of Conduct 3.2.1.2.1  The Plastic Omnium Code of Conduct, which has been the cornerstone of the Group's ethics policy since 2003, was reviewed in 2014 and then again in 2018 to strengthen the anti-corruption measures in response to the Sapin 2 law. Now translated into 22 languages, compared to 8 for the previous version, the Code of Conduct has been issued to all employees and is accessible on the Plastic Omnium company website and intranet. The Code of Conduct lays out the seven respective commitments entered into by Plastic Omnium and its employees. The first part outlines the rules the Group has set itself in terms of respect for human rights, fundamental freedoms, health/safety, diversity, the environment, preventing discrimination, fraud, corruption and influence-peddling. In the second part, the Group asks its employees to commit to protecting Plastic Omnium’s assets and image, ensuring product quality and safety, and adhere to ethics rules and regulations. Some chapters of this Code of Conduct are developed further in supplementary documents, notably the Code of Compliance with competition law, the insider trading prevention charter, the good practice Guide for IT security, and the “Internal control fundamentals and golden rules”. Whistleblowing procedure 3.2.1.2.2 Employees can use the whistleblowing procedure to report behavior or situations which infringe the Code of Conduct. Plastic Omnium has strengthened this procedure by widening the topics covered to all commitments of the Code of Conduct and applying them to external stakeholders. The whistleblowing system is covered in the Code of Conduct, and the procedure to be followed has been translated into 22 languages; it can be accessed on the Plastic Omnium intranet and website. The whistleblowing procedure was submitted to the employee representative bodies and the European Consultation Committee. Plastic Omnium encourages employees to approach their line manager and/or ethics point person in the first instance. In the event of any problems, they can report incidents by letter (Compagnie Plastic Omnium, Ethics Alert, 1 allée Pierre Burelle, 92300 Levallois Perret) or email (corporatesecretary.ethicsalert@plasticomnium.com ) to the dedicated address which only the Group's Corporate Secretary can access. Plastic Omnium is also committed to processing incidents anonymously. Plastic Omnium is also working to protect the rights of whistle-blowers who have acted in good faith and impartially by protecting their identity and ensuring that they will not be subject to any disciplinary action, even if the allegations later prove to have been inaccurate and/or are not followed up. Mapping of corruption risks 3.2.1.2.3 In 2018, the Plastic Omnium Group mapped its corruption risks, identifying all risks and classifying them according to impact and likelihood. This mapping is based on around twenty internal interviews (across all of the Group’s functions and regions) and an analysis of the existing prevention procedures. This mapping exercise also highlighted the steps required to complete the prevention initiative, particularly as regards third-party evaluations, training and internal control procedures. All of this information has been submitted to senior management. Third-party evaluation procedures 3.2.1.2.4 Plastic Omnium wants to ensure that it only works with stakeholders, particularly suppliers, that abide by the same ethics rules as those that it imposes on itself. In 2018, Plastic Omnium tightened up its supplier selection and surveillance processes in terms of both financial sustainability aspects and social, environmental and ethics aspects. These processes covered the following: inclusion of new suppliers on an approved panel; ● suppliers signing up to Plastic Omnium’s Supplier CSR Charter; ● supplier audits on-site or via a self-assessment questionnaire; ● encouraging regular competition between suppliers; ●