Saint-Gobain // Universal Registration Document 2021

6 Risks and control Risk factors SAINT-GOBAIN UNIVERSAL REGISTRATION DOCUMENT 2021 233 Legal risks 1.4 Risks associated with legal and 1.4.1 administrative procedures The Group is exposed to risks of litigation and claims arising in the normal course of business. The most significant disputes pending or for which the Group has received notifications are described below. These proceedings may result in a conviction, the payment of substantial damages, regulatory or even criminal sanctions, and may tarnish the Group’s reputation and thus have a significant negative impact on the Group’s image, financial position and operating results. The total provision for litigation and proceedings amounted to €155 million as of December 31, 2021 (see Chapter 8, Section 1, note 9 to the consolidated financial statements). Anti-trust law and related proceedings* 1.4.1.1 Competition laws apply to the Group companies in countries in which it operates. Violation of competition law exposes the Group to fines and, in certain countries, potential criminal sanctions on the Group and its employees involved. Any litigation filed by a competition authority could, in the event of conviction, give rise to the payment of fines and potentially damages, which is likely to have a significant impact on the Group’s reputation, financial situation and operating results. The Saint-Gobain Group is firmly committed to opposing any practice that might violate competition rules and has long applied the principle of zero tolerance. A competition law compliance program has been in place within the Group since 2007. The content of this plan is described further in Chapter 3, Section 1.2.2. Investigation by the Swiss Competition Commission in the sanitary products wholesale industry In November 2011, the Swiss Competition Commission (Commission suisse de la concurrence) opened an investigation into anti-competitive practices in the sanitary products wholesale industry. In May 2014, the Commission Secretariat issued a notice of complaints against Sanitas Troesch and other wholesalers in the industry alleging that Sanitas Troesch and some of its competitors had, among other things, agreed in 2005 and 2012 to lower gross prices. The total fine imposed on all companies involved is CHF 80 million. For Sanitas Troesch, the fine is CHF 28.8 million. Sanitas Troesch appealed this decision on May 2, 2016 and continues to firmly refute the claims made. The hearing took place before the Federal Administrative Court on January 21, 2020 and the date on which the Federal Administrative Court will issue its decision is not yet known. However, a provision for claims and litigation was recognized at December 31, 2015 in an amount equivalent to the fine (unchanged as at December 31, 2021). Investigation by the French Competition Authority in the building insulation products industry On July 28, 2014, the French Competition Authority sent a statement of objections to Saint-Gobain Isover and Compagnie de Saint-Gobain (as parent company of the Saint-Gobain Group). A hearing took place on May 11, 2016, whereupon the Competition Authority sent the case back for further investigation in light of the arguments put forward by Saint-Gobain Isover and Compagnie de Saint-Gobain. In October 2018, Saint-Gobain Isover and Compagnie de Saint-Gobain received a second statement of objections, in which the Competition Authority alleges anti-competitive practices in the building insulation products market, between 2001 and 2013. Saint-Gobain Isover and Compagnie de Saint-Gobain rejected the allegations in their response to the second statement of objections filed in January 2019. A new report was sent by the Authority at the end of 2019, which gave rise to comments in response from Saint Gobain Isover and Compagnie de Saint-Gobain on February 11, 2020. The hearing before the Competition Authority was held on October 6, 2020. By decision dated January 14, 2021, the French Competition Authority considered that the alleged anti-competitive practices were not established and dismissed all the objections notified. Actis appealed this decision to the Paris Court of Appeal on February 26, 2021, following which the other parties, including Saint-Gobain Isover and Compagnie de Saint-Gobain filed incidental appeals. Hearing is expected to occur end of 2022. On the civil law front, Actis served in March 2013 a damages claim on Saint-Gobain Isover, the Centre scientifique et technique du bâtiment, and the FILMM before the Paris Civil Court (Tribunal judiciaire de Paris) based on the facts being investigated by the Competition Authority. A stay of proceedings has been declared and following the dismissal decided by the Competition Authority and the appeal filed by Actis against such dismissal, Actis requested that the proceeding remain stayed until the Paris Court of Appeal’s decision to be made in relation to the appeal filed by Actis against the dismissal decision of the Competition Authority. The Court granted this request and stayed the proceeding until the Paris Court of Appeal's decision. Asbestos-related litigation 1.4.1.2 Current legal actions related to asbestos are described below. Asbestos-related litigation in France Inexcusable fault lawsuits In France, where Everite and Saint-Gobain PAM had carried out fiber-cement operations in the past, seven additional lawsuits to those brought since 1996 were filed in 2021 by former employees (or persons claiming through them) for recognition of inexcusable fault resulting from exposure for asbestos-related occupational diseases.

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