Saint-Gobain // Universal Registration Document 2021

3 An efficient and responsible Group Demonstrate ethics and responsibility SAINT-GOBAIN UNIVERSAL REGISTRATION DOCUMENT 2021 76 In accordance with this procedure, purchasing categories or suppliers with specific risks have been identified, such as: purchases of certain natural raw materials such as ■ wood or sand; certain types of subcontractors working directly on ■ Saint-Gobain sites; purchases made in countries exposed to risks regarding ■ human rights in general and child labor, corruption and working conditions in particular. Risk management and mitigation 1.4.2 measures The process and tools used to manage risks for trade and non-trade purchases were aligned. However, the action plans put in place are specific to each of the two purchasing teams, to maintain management methods and a level of control adapted to the risks and potential negative impacts of each of the activities. For non-trade purchases Depending on the level of risk identified, suppliers answer an evaluation questionnaire based on documentation, that is verified and evaluated by a third party and, depending on the results, an on-site CSR audit takes place. The entire approach forms part of a constant dialogue with the supplier and leads to the establishment of action plans and CSR performance improvement plans. In 2018, the evaluation questionnaire and its related score scale were reviewed to check that they corresponded to the types and levels of risks identified by the mapping. In 2021, following the reassessment of the minimum performance thresholds, the suppliers concerned were invited to undergo a new assessment in order to comply with the Group's reinforced requirements. The Group set itself the objective, for the 2017-2021 period, of assessing the CSR performance of more than 90% of suppliers deemed to pose a risk and which achieve annual revenue of more than €100,000 with the Group. About CSR audits, the objective is to conduct around 40 to 50 audits a year, mainly in emerging countries. These audits may lead to de-listings if critical failings are identified, or if the necessary corrective plans are not implemented within the agreed periods. The use of the “SMETA 4-Pillar” standard for on-site audits is widespread, so that suppliers’ auditing efforts can be better shared with all of their customers. Based on the results of the assessments, the relevant buyer implements a corrective action plan with the supplier, including priorities and deadlines for implementation. tenders and all entities of the latter will withdraw from any ongoing partnerships. In the event of non-compliance with these action plans, a supplier de-listing policy is applicable, after which the supplier will no longer have access to the Group’s calls for The Responsible Purchasing policy is being rolled out to non-trade suppliers via a private digital platform developed by Saint-Gobain and entirely dedicated to responsible purchasing. Suppliers have access to it to acknowledge receipt of the Group Suppliers Charter, to send essential supporting documents electronically (wood certificates, quality certificates, ISO standards), to answer self-assessment questionnaires, to obtain all information on Saint-Gobain’s “responsible purchasing” guidelines and to access details of their CSR evaluations or, where appropriate, CSR audits. The responsible purchasing approach also includes ongoing training for buyers on the Group code of ethics, with particular emphasis on the fight against corruption, the working conditions of employees of suppliers, forced labor and child labor. Constant information on the sustainable development stakes is also communicated. The Department of Non-Trade Purchasing has issued a “Best Practices” brochure for all purchasers, to remind them of the CSR best practices to be built into the whole of the purchasing process. For trade purchases The procedures and tools were aligned with those already in place for non-trade purchases. Given the different nature of purchases, certain risk criteria and their weighting and performance monitoring are managed separately by the marketing and purchasing teams of the distribution entities. The program is overseen by a team from the Group’s responsible purchasing team. Accordingly, synergies and best practices for responsible purchasing are shared between the various buyers, while a measure of performance adapted to operational risks and opportunities is maintained. This implementation was accompanied by training sessions for buyers. Strategic suppliers are primarily affected by the deployment of the Responsible Purchasing program. This involves the European supplier partners of the distribution entities that make purchases of more than €3 million and the main suppliers of the brands in each country. These identified suppliers cover more than 79% of trade purchases (see chapter 9, section At the same time, the marketing and purchasing teams of the “Building Distribution” Business Unit are continuing the qualification and control audits of the factories of their own-brand suppliers, especially in India and China. The purpose of these audits is to assess their management system, the environmental, social and legal aspects of production activities, and to ensure the good quality of the products. Following each audit, the supplier receives a report as well as recommendations on compliance with an expected effective date or paths for improvement.