Why do we have this Policy?

Why do we have this Policy? Saint-Gobain Group including Saint-Gobain Prima and all other subsidiaries and affiliates of Saint-Gobain Group (collectively the “Saint-Gobain Group”) commit to conducting business ethically in compliance with the Malaysian Anti-Corruption Commission Act 2009 and all applicable anti-bribery and corruption laws of every country in which Saint-Gobain Group operates. The Board of Directors and Management of Saint-Gobain Group give top priority to the implementation, enforcement and continual improvement of Saint-Gobain Group’s anti-bribery management system. To assist the Board and Management, a Compliance Function is or will be established to oversee the design and effective implementation of Saint-Gobain Group’s anti-bribery management system. Saint-Gobain Group does not condone any form of bribery and corruption. This Anti-Bribery and Corruption Policy (“ABC Policy”), which must be read in conjunction with the Saint-Gobain Group’s ethical code available in the Principles of Conduct and Action (https://www.sgr-paris.saint-gobain.com/sites/sgcom.master/files/pca_en.pdf), Saint-Gobain Group’s anticorruption policy is available at: https://www.saint-gobain.com/en/corporate-responsibility/our-pillars/business-ethics and Saint-Gobain Group’s alert sytem is accessible at: https://www.bkms-system.com/saint-gobain (collectively the “SG’s Ethics and Compliance Policies”). SG’s Ethics and Compliance Policies, serves to provide guidance on how to prevent, deal with and combat bribery and corrupt activities and issues that may arise in the course of business.

Both YOU and Saint-Gobain Group shall and shall cause any third-parties involved on our behalf to comply with applicable laws and regulations including without limitation those relating to: (i) employees’ rights (including occupational health and safety, prohibition of forced and dissimulated labor and child labor), (ii) environmental law, (iii) financial probity (including anti-money laundering and terrorism financing, the prohibition of any act of influence peddling or corruption whether active or passive, direct or indirect), (iv) competition law, and (v) trade regulations (including economic and financial sanctions and trade embargoes as well as export control and import laws).

YOU represent and warrant to fulfil the obligations set forth in this Policy. Both YOU and Saint-Gobain Group shall implement proportionate internal measures and procedures to comply with and prevent any breach of the above-mentioned obligations and agrees to communicate them to the other upon request.

Who does this Policy apply to?

This Policy applies to all employees, directors (executive and non-executive) and any person who performs services for or on behalf of Saint-Gobain Group, which includes contractors, subcontractors, consultants, suppliers, agents, intermediaries and representatives of Saint-Gobain Group (collectively, “Applicable Persons”).

An electronic version of this Anticorruption Policy is available at: https://www.saint-gobain.com/sites/saint-gobain.com/files/media/document/2021-07/politique_anticorruption_va.pdf