Saint-Gobain // Universal Registration Document 2021

3 An efficient and responsible Group Demonstrate ethics and responsibility SAINT-GOBAIN UNIVERSAL REGISTRATION DOCUMENT 2021 71 Governance In ethics and compliance, the Board of Directors exercises control over Senior Management. As such, its role is twofold: it ensures that ethics and compliance issues are taken ■ into account in major strategic choices; it ensures that the ethics and compliance program is ■ properly implemented. The involvement of Senior Management is crucial for ethics and compliance. It promotes and disseminates the culture of compliance, demonstrating its commitment through the following actions: taking into account ethics and compliance issues in ■ strategic projects or decisions; implementing the ethics and compliance program with ■ the support of the Ethics and Compliance Department; communicating internally and externally on its overall ■ support for ethics and compliance programs, particularly regarding zero tolerance for corruption and the whistle-blowing system. Ethics and Compliance Department Its mission is to promote the Principles of Conduct and Action and to design and implement the Group’s ethics and compliance program in the areas of business ethics, competition law, the fight against corruption and influence peddling, economic sanctions and export controls, the duty of care and human rights. It identifies and assesses risks, and proposes policies, procedures and programs to control and reduce those risks. Finally, the Ethics and Compliance Department develops and provides training and communication for the programs. It relies on a network of Ethics and Compliance Officers in regions and operations whose mission is to ensure the effective deployment of programs within their scope. Beyond that, Business Compliance Correspondents (BCC) in the countries and Business Units have the role of ensuring the dissemination and knowledge, within their scope, of the Group’s ethics and compliance program and culture.