Plastic Omnium - 2018 Registration Document

3 STATEMENT OF NON-FINANCIAL PERFORMANCE CSR integrated in the business lines PLASTIC OMNIUM 2018 REGISTRATION DOCUMENT 99 The sites with the best practice and results in the fields of health/safety and the environment following self-assessment receive Group-level HSE Awards given at Group level. Each site self-assesses its progress in these fields using a comparable method so that the Group can understand best practices to share and the gaps which need to be corrected. When they join the approved supplier list, suppliers must sign the Supplier CSR Charter and the Conditions of Supply. The General Terms and Conditions of Supply set out different CSR requirements for each purchase category; Plastic Omnium reserves the right to ask some suppliers for ISO 14001 or ISO 45001 certification. At the end of 2018, 587 suppliers were ISO 14001 certified. For companies with their own Ethics Code, compliance of this Code with the Group’s Supplier CSR Charter will be checked: any gaps must be identified, and the Group will decide whether these differences are acceptable. The Plastic Omnium Supplier CSR Charter is based on a mutual commitment between the Group and its suppliers to comply with: the United Nations’ Universal Declaration of Human Rights and its two ● covenants (the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights); the Fundamental Conventions of the ILO (International Labour ● Organization) and the ILO Declaration on fundamental labor principles and rights; the OECD Guidelines. ● Therefore, child labor, forced labor, illegal work and discrimination are prohibited. Equal pay, the right to organize, protection of employment rights and the right to a safe and healthy work environment must be guaranteed. The minimum wage, benefits and maximum working times and environmental protection measures must comply with applicable local legislation. Suppliers must also manage their environmental impacts, optimize and trace the use of resources and replace toxic chemical substances wherever possible. Furthermore, suppliers agree to ensure that their own suppliers, service providers and subcontractors comply with these rules. For suppliers already on the panel, the Supplier CSR Charter has been sent to strategic and critical suppliers. At end 2018, 6,660 suppliers had signed and returned the Charter, an increase on the 4,000 at end 2017. The Charter will be rolled out to more suppliers to 2019. After suppliers have signed the Charter, the next stage involves completing a self-assessment. This simple questionnaire, created in 2018, enables suppliers to show their compliance with the requirements of the Charter. At end 2018, 73% of 261 questionnaires sent had been returned by suppliers. Third mechanism in the assessment process: on-site audits. If gaps are identified during analysis of the self-assessment questionnaire, information may be checked on-site in a specific audit. CSR information now forms an integral part of the audit framework for all audits, such as quality audits. Buyers and quality control personnel have been trained to successfully implement these new audit formats. The inclusion of a supplier on the approved list is also an opportunity to carry out an initial audit covering a range of topics, such as quality, finance, strategy, commercial, etc. but also CSR. In total, 208 suppliers had been through a CSR audit in 2018 and 506 according to Top Safety assessment. Actions to prevent or mitigate violations 3.2.1.3.3 the tools and resources (presented in chapter 3.2.2.), care for people and sustainable production (presented in chapter 3.2.3) are implemented to achieve better results. The dedicated networks and audits make it possible to quickly identify any gaps and take appropriate corrective measures. The various rules and procedures outlined in the Code of Conduct, the “Fundamentals and Golden Rules of Internal Control” and the IT Charter have legal scope. Therefore, failure to comply with them may lead to disciplinary action, as provided for in the employment contracts. Human Resources and HSE policies and procedures reduce the risks as much as possible: training and information sessions, the introduction of Achieving an HSE criterion had until now been included in the 5 objectives of employees having an annual assessment interview. To boost employee commitment to the scope of actions, this HSE criterion will become a CSR criterion in 2019. At Clean Energy Systems, as of 2018, buyers have had their first objective dedicated to managing the responsible purchasing policy, with an impact on their final assessment. Suppliers whose self-assessment highlights any gaps will be quickly audited by the buyers and quality officers, who will then decide on the need to implement an action plan, its schedule and potentially setting a date for another audit. In the event of a major gap on topics deemed by Plastic Omnium to be non-negotiable, the Group reserves the right to take all protective measures to ensure the integrity and sustainability of the Group. Plastic Omnium works closely with its suppliers on certain topics: conflict minerals: Plastic Omnium has a policy to ensure that its supply ● of materials known as conflict materials (gold, tungsten, tin and tantalum and their by-products) is ethical and does not come from sources which support human trafficking, slavery, forced labor, child labor, war crimes, etc; the supply of chemical products: products covered by the European ● REACH regulation must be registered. Plastic Omnium is working with an external service provider to ensure that products meet regulations and that the safety data sheets (which provide information on risks and stipulate usage precautions) are up to date. Whistleblowing procedure 3.2.1.3.4 The whistleblowing procedure was improved in 2018 and a document outlining its procedure for using it has been drawn up and translated into 22 languages. These were presented to the employee representative bodies and the European Consultation Committee, and are available on the Topnet intranet. The relevant topics have been identified and include risks of infringements of human rights and fundamental freedoms, harm to personal health/safety and the environment, as well as ethics risks (corruption, influence-peddling, etc.), whether these risks are identified internally or with service providers, subcontractors and suppliers working for Plastic Omnium. This whistleblowing right has several stages: in the first place, employees who have observed a risk or an offense ● must speak to their line manager or management at the level above; if there is any difficulty in discussing the matter with these people, the internal ● hotline must be used. There are two ways to use it: letter (Compagnie Plastic Omnium, Aehtics Alert, 1 allée Pierre Burelle, 92300 Levallois Perret) or e-mail ( corporatesecretary.ethicsalert@plasticomnium.com) . The information is covered in the Code of Conduct, the website and the TopNet intranet. The incident must be reported exclusively to the Corporate Secretary. People outside of Plastic Omnium may also use this mechanism; the e-mail address can be found on the Group’s website.