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 98 The two analyses have been cross-referenced to correlate the results: the risk sources are the same. Specifically, analyses are conducted by topic or locally. Accordingly, corruption risk mapping took place in 2018, and information systems risks were also mapped (see Chapter 3.2.1.4 Data protection). The Internal Audit framework covers risks linked to human rights and fundamental freedoms: forced labor, child labor, duration of work, overtime hours, compensation, subcontracting, etc. These were identified as high-risk areas requiring controls and, if necessary, action plans. ISO 45001 certification (obligatory for all sites) requires a risk analysis to be carried out: each site certified or applying for certification (for new sites) has completed its risk mapping and risk ratings, and implemented measures to prevent, reduce or correct the risks. Furthermore, ergonomics on workstations have been analyzed to identify and reduce risks (for further details, please refer to Chapter 3.2.2.2 Occupational health and safety conditions). Site visits by managers and Top Safety visits are an opportunity to identify high-risk situations and implement corrective measures. The engagement survey conducted in 2016 contained questions on working conditions, psycho-social risks and health and safety, making it possible to monitor local workplace risks at a granular level. Sites obliged to obtain ISO 14001 certification must also undertake a local environmental risk analysis and update it regularly. The calculation of the Group’s overall carbon footprint and the ongoing life cycle analyses identify major impacts and areas for improvement at each product life stage and across all of the Group’s operations. In 2018, supplier categories were defined by critical level and the level of their relations with the Group. A supplier is considered critical if it supplies strategic products (BOM purchases  (1) and raw materials) or if, for purchases of services and investments (machines, equipment, etc.), the supplier presents a potential risk (new supplier, mutual dependence, monopoly situation, gap identified during audits, significance of investment, failure to meet CSR criteria, etc.). Special attention will also be paid to intermediaries: companies or people acting on Plastic Omnium’s behalf in certain specific areas (marketing and sales, contract negotiations and securing of licenses, permits or other authorizations) and any activity which benefits the Group. To be added to the approved supplier list, new suppliers must undergo an evaluation audit to ensure they meet Plastic Omnium’s standards. Checks on respect for human rights and fundamental freedoms, health and safety and environmental policy are among the criteria. The supplier’s score determines their level of priority for the assessment. For suppliers already on the approved list, the first stage sets out the ranking for the assessment: in 2019, the Group will use a supplier database tool recognized by the automotive sector. Suppliers’ financial and CSR information will be made available, making it possible to target those suppliers whose information does not meet the Group’s expectations. As a priority, critical suppliers (around 600), intermediaries, new suppliers and suppliers responding to a new call for bids will be included in the database, and the results will be analyzed. The procedure Plastic Omnium uses to evaluate suppliers’ consideration of CSR issues will be defined according to the supplier category, critical or intermediary, as the risks are different. Evaluation procedures 3.2.1.3.2 The Code of Conduct, which was strengthened in 2018, sets out the Plastic Omnium’s and its employees’ commitments as regards human rights, fundamental freedoms, health, safety, ethics and environment: compliance with the international standards of the ILO (International Labor Organization) on child labor; forced labor, discrimination, bullying and sexual harassment are prohibited; freedom of association and expression are protected. Joining the United Nations Global Compact is proof of these commitments. Complementary policies and procedures set out the rights and duties of each individual: Code of Compliance with competition law, health and safety policy, Top Planet policy, IT Charter, “Fundamentals and Golden Rules of Internal Control”, etc. These issues are mainly championed by the HR, HSE / CSR and Risk Management and Internal Audit Departments, and are circulated across all business lines and all sites by networks of internal point persons. To ensure that all those concerned understand the rules and standards they are expected to comply with, information, training and awareness-raising campaigns are in place to back up these initiatives. The MyLearningPlace tool contains e-learning modules on ethics, compliance and ergonomics. The modules must be successfully completed. Face-to-face and blended learning sessions complete this initiative and provide information and training on other topics: environment, health/safety, responsible management, etc. Participation in information and training sessions is monitored by the Group, which manages all topics using key performance indicators and monitoring indicators. A reporting tool is used to manage employee and environmental indicators, and the main results are submitted to the Executive Committee three times a year for discussion. These meetings provide an opportunity to assess the effectiveness of the policies in place, understand any gaps and set targets. Two annual presentations will be given before the European Consultation Committee on the policies, tools and results. Audits by the Internal Audit Department verify that the procedures are applied across all sites. These audits may be planned or unscheduled, and cover the principles of the United Nations Global Compact: ethics, human rights, international labor standards, child labor, forced labor, working hours, overtime hours, compensation, safety and environmental protection. The sites are audited every three years, and more frequently where major gaps are detected. In 2018, 32 sites were audited. The management of the Divisions and support functions are updated every month on the audits, and on any issues identified which require immediate correction. The Audit Committee receives the results of the audits every year. The Top Safety visits dedicated to safety complete the set of safety initiatives, and the ISO 14001 and ISO 45001 certifications bring an additional external audit. BOM (Bill Of Materials) = finished raw material or by-products used in the composition of a product. (1)