Saint Gobain - Registration document 2016

4 AN EFFICIENT AND RESPONSIBLE GROUP 1. Reference policies

1.

Reference policies

1.1

THE COMPLIANCE CULTURE

Teams in charge at all Group levels The compliance program is monitored by the Board of Directors of Compagnie de Saint-Gobain. Its implementation General Secretary and composed of more than 100 functional operating managers who are members of Compliance is based on a compliance network, coordinated by the Committees within the Group and the General Delegations.

The compliance culture that drives the Group is developed through its values, formalized in 2003 in the Principles of Conduct and Action (see chapter 1, section 2.2.1). program since 2009 which strengthens the effective application of the Principles of Conduct and Action and the This compliance culture has been supported by a full worldwide. resulting obligations, in all the Group’s Activities and Compliance is an ongoing obligation that applies to all employees. As regularly noted by the Group’s General Management, the principle of zero tolerance is required. At all hierarchical levels, it becomes obvious for committed managers. Regularly enriched since its launch, the compliance program is today focused on into the following main subjects: compliance with the rules on anti-trust law: the ‹ audits, availability of practical guides and newsletters but also dedicated teams for all operational questions on the Competition Law Plan is composed of various training measures (online and in-person), the performance of based on the management of measures and good practices already implemented in various subsidiaries to prevention of corruption: the anti-corruption program is ‹ prevent the risk specifically connected with international commercial transactions; it targets passive and active subject; corruption in relations with public officials and the private sector; it is composed of training tools (online and in-person), internal policies (gifts, conflicts of interest, agents, etc.) and is monitored by a network of correspondents by General Delegation and by Sector that external lawyers. for which screening tools, training (online and in-person) and specific policies are also applied, as well as active compliance with economic sanctions and with embargos ‹ monitoring of changes in close association with specialist This results in a well-established and well-structured compliance culture. Disseminated by the Group’s General Management and passed on to all Group levels by the managers and the compliance network, it is constantly developing based on topical subjects. answer operating questions on this subject;

THE COMPLIANCE NETWORK

COUNTRIES AND SECTORS COMPLIANCE CORRESPONDENTS 35 PERSONS

GROUP GROUP COMPLIANCE COMMITTEE 9 MEMBERS

DELEGATIONS COMPLIANCE COMMITTEE (1 PER DELEGATION) 65 PERSONS

At operational level, the application of our values and our compliance culture is supported by: both internally and externally; the General Management, which refers to them regularly, ‹ promotes the Principles of Conduct and Action among all employees; the Responsible Development Department, which ‹ the Legal Department, which draws up and implements ‹ the programs associated with specific themes; the managers, who endorse them and implement them; ‹ the Internal Audit and Control Department (see chapter 7, ‹ section 2), which verifies the effective application thereof.

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SAINT-GOBAIN - REGISTRATION DOCUMENT 2016

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