2021 UNIVERSAL REGISTRATION DOCUMENT

3. Risk factors and control environment

In terms of Human Rights
Results of audits by topic

(i) Child labour: 1.8% non-compliance.

2 audits identified employment of a child under the age of 16. The necessary measures have been taken to discontinue any commercial relationship with the companies concerned. Demands have been made for the children to be sent to school. Other cases of non-conformity were found in the area of “Child Labour”, particularly concerning the absence of procedures to verify age at the time of hiring by the Supplier, and the absence of copies of identity documents. The Suppliers concerned have been asked to correct this situation, and follow-up audits are planned.

(ii) Forced labour: 6.7% of non-compliances ☑.

One audit found employees who are bonded or under contract either with the company itself or with a broker. The necessary measures have been taken to discontinue any commercial relationship with the companies concerned. Other cases of non-conformity concern the demand for a monetary deposit at the time of hiring, with holding of identity documents without a legal requirement, as well as the freedom for employees to end their contracts without being penalised (financially or other) except for those stipulated by social legislation. The main corrective measures requested were the return of the identity documents and the updating of employee contracts. Follow-up audits will check the effective implementation of these corrective measures.

(iii) Freedom of association(1): 2.1% non-compliance ☑.

Most of the cases of non-conformity concern the failure to freely elect employee representatives without management interference. Elections must be carried out, or in countries where such elections are not legal, employee meetings must be organised to report items to be improved.

(iv) Non-discrimination: 1.1% of non-compliances ☑.

These cases of non-conformity mainly concern the absence of a clear and uniform policy to ensure the absence of discrimination at recruitment or discrimination in the payment of wages and other costs. Suppliers were requested to implement such policies, which will be checked in future audits.

(v) Working hours: 24% of non-compliances ☑.

Cases of non-conformity involved failure to comply with the Applicable Rules for work time and regular days off, but also the lack of sufficient documents to ensure correct monitoring of the Applicable Rules. In all of these cases, action plans are implemented and a follow-up audit is planned.

(vi) Wages and charges: 19% of non-compliances ☑.

The audits did not find undue salary with holding or charges.

Most of the cases of non-conformity concerned insurance and social contributions as well as a failure to monitor payments of wages. When an audit notes a case of non–compliance with regard to the correct settlement of wages, social benefits or the correct payment of overtime, even though these are not undue salary deductions, the Suppliers are requested to correct the situation and a follow-up audit is planned.

Sexual harassment and bullying: 2.4% non-compliance.

Most of these cases of non-conformity concerned the absence of a written policy prohibiting sexual harassment and bullying or the absence of an internal system allowing the situation to be reported without negative consequences for the employee concerned.

Suppliers were requested to draft these policies, which will be checked in future audits.

The other cases of non-conformity did not concern serious breaches of the Applicable Rules.

Health, Safety and the Environment

41% of the cases of non-compliance concerned the applicable rules on Health, Safety and the Environment.

Most of these cases concerned (i) the absence of fire safety certification, (ii) the lack of training in emergency evacuation, extinguisher handling or the use of protection equipment, or (iii) access to running water flows in all spaces exposed to the use of solvents, corrosive products or other chemical risks.

The missing certifications were obtained from approved third parties, and the training in emergency evacuation and extinguisher handling were implemented as the main corrective measures. Likewise, renovations to adjust the water points were carried out by the Suppliers.

Sustainable sourcing of raw materials

In 2021, 100% of the renewable raw materials used by the Group were reassessed on the basis of criteria such as respect for biodiversity and forced labour. Out of the 313 plant species that are the source of the renewable raw materials used by the Group, around 6%(2) present significant biodiversity challenges (endangered species, impact of production on natural environments) depending on their geographic origin and the method of extraction or production used. They are the subject of specific action plans initiated with suppliers and, if necessary, benefit from the systematic support of independent external third parties, in order to manage the real impacts on the territories of origin of the ingredients.

The Statutory Auditors have expressed reasonable assurance about this indicator.

(1) Figures exclude audits where verification could not be performed because of the specific nature of local regulations.

(2) Calculated on the basis of projected purchases between January and November 2021.