General Principles of Conduct and Action

 

The Saint-Gobain Group has developed a number of shared principles applied by both management and employees that have guided the Group’s activities over the years. Today the Group wishes to give written expression to these principles, to help us communicate them and reinforce their implementation throughout the Group worldwide. The purpose of this document is also to make a public statement of Saint-Gobain’s adherence to these basic principles of conduct and action, which apply to all companies within the Group regardless of where they carry on business. These principles are not intended to be exhaustive, but to address the essential areas. They are complemented, and may in the future be further complemented by sometimes more specific rules having regard to local conditions or particular positions of responsibility, but in any case without detracting from the basic principles. Adherence to these principles is a requirement for belonging to the Saint-Gobain Group.

The Saint-Gobain Group considers that the basic values shared by management and employees alike are: professional commitment, respect for others, integrity, loyalty, and solidarity. These principles of conduct apply to each of us.

Professional commitment
means mobilising to the best of one’s ability the knowledge and know-how of the individual and also calls for training to keep both up to date. It requires personal commitment and a willingness to take on the tasks assigned and to acquire knowledge necessary to do the job. It implies the effective contribution of each person in caring particularly for the environment and for worker health and safety.

Respect for others
is an absolute prerequisite for the professional and personal development of each person. It applies throughout the Group worldwide. It implies an acceptance of pluralism and other cultures and of people of all origins. It is expressed in a readiness to listen to others, to inform, to explain, and to engage in dialogue.

Integrity
requires a rigorous adherence to probity in all professional activities. It means that no individual may compromise the interests of the Group entrusted to that individual in favour of his or her own private interests – whether in dealing within the Group or in dealing on behalf of the Group with third parties, whatever local practices might be. Detailed rules of conduct may be adopted for certain categories of Group personnel where the nature of their responsibilities so requires.

Loyalty
requires honesty and fairness in dealing with superiors, colleagues, subordinates and third parties dealing with the Group. In particular, it is incompatible with the pursuit of self-interest where the latter conflicts with the goals of the individual company or the Group as a whole. It implies the adherence to the guidelines and internal rules of individual companies and of the Group.

Solidarity
is based on a sense of individual responsibility at work, which prevails over self-centered thinking. It encourages team work and bringing out the best in each person, in order to achieve the objectives of the company and the Group. It means rejecting management or operational methods geared more to the self-satisfaction of given individuals rather than the interests of the individual company or the Group as a whole.

Principles of Action
The Saint-Gobain Group wishes to set out the principles of action which govern the activities of all management teams and employees in the exercise of their professional responsibilities, regardless of the country involved. These principles of action(1) help us achieve responsible and sustainable growth, in accordance with the Group’s long-term strategy.

Respect for the law
All Group companies must apply in all areas all laws and regulations of the countries where they do business. Particular attention is drawn to the areas described below. All Group companies must prohibit all actions which might breach applicable norms of competition law. They must refrain from any form of financing political parties or activities, even if allowed under local law. They must also reject all forms of active or passive corruption whether in domestic
or international transactions(2).
Furthermore, Group companies must not exploit loopholes or inadequacies in any such laws or regulations where this would mean non-compliance with the norms of the Saint- Gobain Group in the areas described below.

Caring for the environment
Group companies are to actively promote the protection of the environment.
All company sites, wherever they are located, must be man- aged in a way that allows the setting of clear environmental targets and the regular monitoring of environmental performances and measuring the same against these targets. They must strive to raise the main relevant environmental performance standards of their own sites to the level of particularly effective performance standards found in the Group for comparable sites – even if that means going beyond the requirements of local legislation.

Worker health and safety
Group companies are to take particular care to adopt all measures necessary to ensure the best possible protection against health and safety risks in the workplace.
They must adopt risk reduction policies and follow-up on the due application of the same, checking actual results against the applicable standards. Such policies apply both to their own employees and to employees of sub-contractors, when the latter are working on a Group site.
They must strive to raise the main relevant health and safety performance standards of their own sites to the levels of particularly effective performance standards found in the Group for comparable sites – even if that means going beyond the requirements of local legislation.

Employee rights
Group companies must scrupulously ensure that employees’ rights are respected. They must promote an active dialogue with their employees.
In addition, and without limitation, they must respect the following rules, even if not provided for by applicable local law. They must refrain from any form of recourse to forced labour, compulsory labour, or child labour(3) – whether directly or indirectly or through sub-contractors when the latter are working on a Group site; and they must refrain from any form of discrimination with respect to their employees, whether in the recruitment process, at hiring, or during or at the end of the employment relationship.

People at every level in the Saint-Gobain Group
are individually responsible for applying these principles of conduct and action.
Each management level – company, business unit, Delegation or Sector, carries its own responsibility for ensuring that these principles are applied.
The Sectors and Delegations must report regularly to the general management of the Group on how these principles are being applied.
The general management of the Group will implement awareness and training programmes in order to promote these principles across the Group. It will decide on appropriate methods to verify compliance.