Plastic Omnium - 2020 Universal Registration Document

STATEMENT OF NON-FINANCIAL PERFORMANCE The ACT FOR ALL TM program www.plasticomnium.com PLASTIC OMNIUM UNIVERSAL REGISTRATION DOCUMENT 2020 154 Assessment measures 4.6.1.2.2 Several systems are in place to assess the performance of subsidiaries in different areas. Indicators are monitored very regularly using a reporting tool dedicated to labor management control and environmental performance monitoring. Data are monitored on a monthly, quarterly or annual basis; changes in data, discrepancies and possible deviations are easily identified. The main results are presented to the Executive Committee during dedicated HSE meetings and during ACT FOR ALL TM Committees. These results are used to set the main guidelines and targets, to define policies and to analyze deployment and any gaps. The main results are also presented twice a year to the European Works Council. In addition, the Internal Audit Department plans an annual program of control visits to subsidiaries and sites. Site audits were carried out as planned during the months of January, February and March and then between June and August. This program was adapted during the lockdown periods. They were carried out remotely and supplemented by the use of a local auditor to carry out additional investigations and visual checks (photos, videoconferences, use of virtual reality tools). For approved suppliers, a system comprising three tools was put in place in 2019: A database incorporating the financial information plus the 1. sustainability data: the database is increased each year. For suppliers who are part of a group, Plastic Omnium collects data from the parent companies; The Suppliers’ Charter: if approved, Plastic Omnium requires each 2. supplier to sign the Group’s Suppliers’ Charter. Equivalence with their own charters, if comparable, is accepted. The Suppliers’ Charter is available on the website. Deployed since 2016, it is built around the following references: the United Nations’ Universal Declaration of Human Rights and its ● two additional covenants (the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights); the ten principles of the United Nations Global Compact; ● the Fundamental Conventions of the ILO (International Labor ● Organization) and the ILO Declaration on fundamental labor principles and rights; the OECD Guidelines. ● The suppliers undertake to comply with: competition law; ● laws and regulations aiming to combat corruption and money ● laundering; human rights and working conditions: prohibition of the use of forced ● or compulsory labor in all its forms, the use of child labor, prohibition of discrimination in terms of employment and working conditions and guarantee of equal pay and freedom of association and protection of the right to organize. Finally, they are committed to maintaining a safe and healthy work environment. In the event of breach, Plastic Omnium may require the Supplier to take corrective measures or terminate all or part of the contract for negligent non-performance. A sustainability assessment by an external third party: Plastic 3. Omnium has chosen EcoVadis as a partner to assess its supply chain. In 2020, the assessment methodology for suppliers has been refined. The three tools in the supplier assessment system enable Plastic Omnium to categorize suppliers into three levels of risk: green, yellow or red. In 2021, these risk levels will be used to define the purchasing policy by risk level. An additional control is carried out through the ISO 14001, ISO 45001 (or OHSAS 18001) and ISO 50001 certifications of the sites. They compare the suppliers’ level of compliance with internal requirements. During the fiscal year, 1,258 suppliers went through the supplier risk assessment system, i.e. 800 additional suppliers compared to last year. The new performance indicator, the Ethical Suppliers Index, a marker for the ACT FOR ALL TM program, weights the deployment rates of these three tools (the database, the Supplier Charter and the sustainability assessment by an external third party). In 2020, it was 90%. Prevention and mitigation actions 4.6.1.2.3 A number of policies and procedures govern the actions of the Group and its subsidiaries. The Code of Ethics is the first instrument governing the actions of the Company and its employees. It outlines the commitments undertaken in terms of respect of human rights, fundamental freedoms, health and safety and the environment. These rules are supplemented by policies and procedures on specific issues: Code of Compliance with competition law, ACT FOR ALL TM program, Top Safety health and safety policy, Top Planet policy, charter for the use of communication means and IT tools, and the “Fundamentals and Golden Rules of internal control.” These policies are defined at Group Department level and deployed in each of the business lines and all sites by the business line departments and networks of internal correspondents. Awareness raising and training programs are deployed among target populations and all employees to ensure that these rules and policies are well understood and applied. In order to prevent, reduce and correct impacts, a panel of policies and procedures has been defined and implemented by the dedicated departments at Group level (HSE and sustainability Department, HR Department, Compliance Department, etc.): the Code of Conduct, the Code of Compliance with competition law, the ● “Fundamentals and Golden Rules of internal control” and the charter on the use of communications means and IT tools have legal scope. In the event of a breach, sanctions may be applied; the ACT FOR ALL TM program, the Top Planet and Top Safety policies: ● defined at Group level and deployed in all business lines, these policies govern desired behavior within Plastic Omnium; commitment in 2003 to the 10 principles of the United Nations Global ● Compact; inclusion of sustainability criteria in the criteria for awarding the ● variable portion of compensation: in 2020, 92% of directors had a sustainability objective in their individual performance plan.