3 An efficient and responsible Group Demonstrate ethics and responsibility www.saint-gobain.com SAINT-GOBAIN UNIVERSAL REGISTRATION DOCUMENT 2021 70 Demonstrate ethics and responsibility 1. Ethics and compliance 1.1 Applying Saint-Gobain’s Principles 1.1.1 of Conduct and Action The Principles of Conduct and Action are the code of ethics that forms the foundation of all of Saint-Gobain’s policies and commitments (see chapter 1, section 2.2.2). They define the values and rules applicable to all Group entities and employees, across all employment contract types (open-ended contracts, fixed-term contracts and temporary staff), and also to their subcontractors and suppliers. This applies in particular to compliance policies, the human rights policy, the Environmental, Health and Safety (EHS) charter, the purchasing and suppliers charters of the responsible purchasing program, and the diversity policy. The code of ethics also sets out the procedures for working with stakeholders, with a particular focus on permanent on-site subcontractors, other subcontractors and suppliers. For this reason, it is translated into 31 languages and is available on the Group’s website for wide distribution to stakeholders. Each employee, including those on fixed-term contracts and temporary staff, receives information during their induction about the code of ethics in the local language. This may take various forms, depending on the country: a welcome brochure with comments from the Human ■ Resources representative; the code of ethics may be appended to the contract of ■ employment. In-person trainings are provided in all countries where Saint-Gobain operates. It is provided either by an Ethics and Compliance Manager or by a local correspondent trained for this purpose. Modules are regularly included in management school sessions. These sessions are adapted to the seniority of the managers; they aim to discuss their daily practices, the difficulties encountered in different cultures, and the way in which values guide decisions. In order to ensure wide deployment in countries, managers, usually from HR or Compliance networks, are trained to provide training on the code of ethics. They can therefore organize sessions for all the employees or for external stakeholders such as suppliers. An e-learning course called “Adhere” is available for all employees and is compulsory for all managers. Throughout the Saint-Gobain University Management School training course, a module dedicated to the code of ethics allows managers to discuss the issues and share their operational experiences. Because of the health crisis, training formats had to be adapted to digital media, with the ambition of maintaining the interactivity that is essential for preserving time to exchange experiences and difficulties encountered. The Group has set itself the goal of training each new manager, from the first year of integration, to the code of ethics, the fight against corruption and compliance with competition law. This objective is included in the CSR dashboard monitored by the Board of Directors (see chapter 4, section 2.1). On June 17, 2021, an event was organized in all the countries where Saint-Gobain operates to promote and discuss its values, the Principles of Conduct and Action. Transparency and trust between colleagues, the defense of human rights, fairness in business practices, the protection of personal data, the integrity of the Group's supply chain and the fight against corruption were the themes discussed on over 2,300 sites, during workshops, conferences, debates and presentations. This event generated a strong mobilization of all the Group's employees. They expressed the importance of the code of ethics in nurturing trust and enabling success as part of the purpose: “Making the World a Better Home”. The event was sponsored by Saint-Gobain's management. A video of the Chairman and Chief Executive Officer, the Deputy CEO and the General Secretary speaking about their experience of ethics was shared with more than 120,000 employees, and the General Secretary's statement posted on the Group's internal social network was viewed more than 45,000 times. Deploying business ethics and 1.1.2 compliance programs At Saint-Gobain, business ethics programs aim to pursue both an ethical and a compliance objective in the conduct of the Group’s business. The Group’s ethics and compliance program is thus designed and implemented as a natural extension of the Group’s values and commitments. While ethics aims to ensure that everyone complies at all times with the values at the heart of the Principles of Conduct and Action, compliance aims to ensure that everyone always complies with laws, regulations and international conventions applicable to the Group, the violation of which is likely to result in penalties (civil, administrative or criminal) for the company, its managers and employees and/or commercial, financial and reputational damage. The ethics and compliance program has been based, since 2009, on the adoption and deployment of appropriate and effective tools (internal policies and procedures, training, whistle-blowing system, reporting, audit) and the promotion of appropriate behaviors.
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