Saint Gobain - Registration document 2016

4 AN EFFICIENT AND RESPONSIBLE GROUP 1. Reference policies

The tools used to implement the program are as follows:

Anti-Corruption Day held on December 9, 2016. the notice from the General Management on ‹ anti-corruption measures during the International The Group also added the anti-bribery training to its objectives on compliance program. As well as for the Principles of Conduct and Action, and the anti-trust rules, all manager joining Saint-Gobain will have to also achieve the online training program ACT on preventing bribery during the first year of presence. So, Saint-Gobain esthablished that 100% of the new managers will have passed the e-learning courses Adhere (Principles of presence, as an objective for 2018 (see chapter 5, section 2.1). Action and Conduct), Comply (competition laws) and Act (anti-corruption prevention) during their first year of Reference points The General Secretary, the Legal Department and the network of Compliance Correspondents work to disseminate the compliance culture within the Group, ensuring the communication of messages, a good understanding of the rules by all employees and checking the correct application of the rules: training program “Comply” on competition law and the online training program “Act” on preventing corruption; Group managers are required to follow the online ‹ compliance; in-person training is organized by the General ‹ Delegations and the Sectors on the subject of Compliance Committees aiming to review the subjects ‹ are organized several times a year for the Group’s General Management and the General Delegations; Activities are adapted and implemented; associations, gifts, conflicts of interest, commercial agents, etc.) are disseminated in the countries and policies on every sensitive subject (professional ‹ audits are organized every year, including compliance ‹ topics. latter are working on a Group site”, such concepts having to be taken within the meaning of the applicable Conventions of forced labor, to compulsory labour or to child labour, either directly or indirectly or through subcontractors when the recruitment, during execution or on termination of their the International Labour Organization. They shall not apply any discrimination whatsoever vis-à-vis their employees, on by performing additional verifications, as needed, in cooperation with the local authority. The Group companies shall verify the age of their employees Similarly, for child labor, the Group companies shall ensure that they are not involved in forced or compulsory labor in any way, particularly through dialog with the personnel representation entities, in an effort to detect any violations. Since 2014, the Group has increased the collection of information on discrimination. The systems for collecting complaints have been improved to favor employee concerns. The clarification of internal definitions has made it possible to contract of employment.

Group employees; a dedicated Intranet, known as Conform’Action, where key ‹ messages are passed on and tools are made available to all training, including various e-learning modules; ‹ dissemination and implementation of internal policies; ‹ internal and external audits; ‹ the compliance alerts system, allowing employees to ‹ report any non-compliance with the applicable laws, the Group’s internal rules and procedures and the Principles of necessary, investigated. When they are found to be justified, appropriate measures are taken. Conduct and Action. All reports are examined and, if Supporting the compliance culture within the Group involves calling upon many participants both centrally and locally. To conducted such as: Correspondents of the General Delegations and Activities in October 2016 and targeted awareness measures were build teams around the subject and identify the main action plans, a seminar brought together all the Compliance the publication of a guide dedicated to purchasers on the ‹ 20 good practices in competition law in April 2016; the publication of a guide intended for all employees ‹ containing measures concerning competition law (the Fil Concurrence [“Competition Line”]) in July 2016;

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RESPECT FOR HUMAN RIGHTS

The first two principles of the Global Compact, which Saint-Gobain joined in 2003 (see chapter 1, section 2.2), invite businesses to “promote and respect the protection of internationally proclaimed human rights within their sphere of influence” (principle 1) and to “make sure that their own companies are not complicit in human rights abuses” (principle 2). In 2008, Pierre-André de Chalendar, Chairman and CEO of Saint-Gobain, signed the statement of support for human rights by company leaders on the occasion of the 60 th anniversary of the Universal Declaration of Human Rights. Saint-Gobain’s values, formalized by the Principles of Conduct and Action, are an essential means of mobilization for human rights owing to their reference to international conventions, particularly the International Charter for Human Rights and the applicable conventions of the International Labour Organization. (Respect for employees’ rights) state that “the Group Companies […] must refrain from any form of recourse to More specifically, the Principles of Conduct and Action

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SAINT-GOBAIN - REGISTRATION DOCUMENT 2016