IMERYS ΒΙΟΜΗΧΑΝΙΚΑ ΟΡΥΚΤΑ ΕΛΛΑΣ ΑΝΩΝΥΜΗ ΕΤΑΙΡΙΑ

1. Strategic, Analysis & Action

ADMINISTRATIVE PRACTICES

Imerys respects the world in which it operates. Imerys is committed to play a role in society, to meet its obligations to the countries and communities within which it does business, and to act as responsible environment stewards and thereby contribute to sustainable development.

Since 2017, the Group CSR program has been overseen by a CSR Steering Committee which meets quarterly and is chaired by the Chief Executive Officer. The Board of Directors reviews the performance and progress made by the Group against its CSR program every year. In 2018, the Group announced the launch of its new CSR program referred to as SustainAgility. The SustainAgility program was developed taking into consideration a wide range of inputs from internal and external stakeholders. The Group continues to develop and roll-out the SustainAgility program in an iterative fashion.

The SustainAgility ambitions are articulated around three axes as outlined in the Group CSR Charter, which was updated in 2018:

• Empowering our people: making sure employees and the people we work with stay healthy and safe, nurturing talent, promoting diversity & inclusion, fostering social dialogue and safeguarding human rights;
• Caring for our planet: protecting the environment, promoting non-energetic resources efficiency, respecting biodiversity, and acting on climate change;
• Building for the future: behaving ethically, operating fairly, ensuring a responsible supply chain, engaging with communities and promoting sustainable products and technologies.

The SustainAgilty program is built around six pillars:

• Safety And Health
• Human Capital
• Environmental Stewardship
• Climate Change
• Business Conduct
• Product Management

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PERFORMANCE INDICATORS

• GRI 102-12 Disclosure: External initiatives

Imerys adheres to major international framework agreements, such as the United Nations Global Compact (UN GC), the United Nations Sustainable Development Goals (SDG), the United Nations Guiding Principles on Business and Human Rights, the Organisation for Economic Co-operation and Development (OECD) guidelines for multinational enterprises, and the International Labour Organization (ILO) Fundamental Conventions.

Imerys supports the ambitions of 17 Sustainable Development Goals (SDG) global program and has duly identified within the SustainAgility program the policies and practices within its operations that directly or indirectly contribute to the SDGs. The Group is specifically focusing on concretely contributing mainly to the SDGs No. 4 Quality Education, No. 12 Responsible Consumption and Production and No. 15 Life on Land.

For additional information regarding Imerys strategy, please refer to 2018 CSR Report (pp. 2-3).

• GRI 102-15 Disclosure: Key impacts, risks and opportunities

Imerys Industrial Minerals Greece S.A. (hereinafter named “Imerys Greece S.A.”) consists the Business Unit of Bentonite and Perlite Intermediates (BPI BU), part of the Metallurgy Division. Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and BS OHSAS 18001:2007 Occupational Health and Safety Management System (OHSMS).

Based on the risk-based approach imposed by ISO 9001:2015 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology and integrated it with the BPI BU process approach. This risk management methodology helped identify not only risks, but also opportunities per process and facility.

The process of risk management consists of the following successive steps:

• Identification of interested parties and their needs and expectations;
• Determination of the processes (e.g. mining, industrial, maintenance, sales, etc.) and their application/ interactions throughout facilities. Moreover, determination of the external issues (opportunities and threats) and internal issues (strengths and weaknesses) that are relevant to the purpose and strategic directions of the facilities;
• Identification and evaluation of potential risks and opportunities (risk and opportunity assessment), as resulted from external and internal issues identification;
• Determination of appropriate actions to reduce risks to acceptable level or to increase the opportunities above the acceptable level;
• Application of the criteria and methods needed to ensure the effective operation and control of these processes, through key performance indicators (KPIs) set and monitoring.

Main risks identified are related to Imerys business, regulation and legal risks, while main opportunities identified are related to new resources/ reserves, new financial markets and advanced human capital.

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2. Materiality

ADMINISTRATIVE PRACTICES

Imerys material CSR challenges and opportunities are summarized below under the six SustainAgilty program pillars:

• Safety and Health

Ensuring the safety and health of employees as well as contractors is Imerys’ number one commitment. Being a safe place to work is a cornerstone of Imerys’ sustainability. Due to the inherent nature of industrial activities, Imerys employees, contractors, customers’ employees may be exposed to risks that, in the event of failings in the safety management hierarchy of controls, could result in a fatality, serious life-changing injuries, or short-term health effects.

• Human Capital

Imerys human capital is the most important Group asset, thus ensuring the respect of human rights and labor practices, developing tools for talent and skills management, maintaining constructive social dialogue and ensuring a diverse and inclusive environment with equal opportunities for all are crucial to the Group long-term strategy.

• Environmental Stewardship

Imerys is resolved to not only ensure full compliance with environmental obligations, duly identifying environmental risks and mitigating impacts, but also to reduce the environmental footprint of operations, optimize the use of mineral resources and processing of mineral solids, limit the consumption of other non-energetic resources such as water, and preserve biodiversity. Other environmental aspects such as hazardous substances and noise and vibration may be significant at a local level and as such are managed accordingly within the site Environmental Management System (EMS).

• Climate Change

Imerys is committed to contribute to reduce the impacts of climate change and is aware of the global trend towards an economy that is low carbon or carbon-free creating a potential transitional risk. For the transformation of industrial minerals, this requires ensuring greater energy efficiency through new technologies and processes as well as integration of renewable energy sources.

• Business Conduct

Ensuring ethical business conduct in a rapidly evolving global business environment is achieved through strong corporate governance, which is the foundation upon which the Group is built. Yet evolving regulations focusing on fair operating practices, and responsible supply chain require continual adaptation of Group systems and processes.

• Product Management

Imerys is fully aware of stakeholders expectations to reduce products environmental footprints while at the same time provide sustainable solutions. Responsible product management contributes to the development of sustainable business opportunities. The technological expertise within Imerys places the Group in an excellent position to continuously improve the process efficiency and production methods of its operations.

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PERFORMANCE INDICATORS

• GRI 102-47 Disclosure: List of material topics

Materiality is about identifying the key issues, threats and opportunities that may negatively impact or have the capacity to create value for Imerys and its stakeholders. The results of the 2018 materiality assessment exercise indicated the most material issues which were:

• Occupational safety management
• Occupational health management
• Environmental management
• Product sustainability
• Fair operating practices and responsible supply chain
• Climate change strategy
• Biodiversity and land rehabilitation
• Diversity and inclusion

By crossing all the data coming from different sources Imerys aims to get a better vision of the most material issues so to orientate its mid and long-term CSR program in an optimal way for the Group and its stakeholders.

For additional information regarding Imerys material CSR risks, please refer to 2018 CSR Report (pp. 5-6).

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3. Objectives

ADMINISTRATIVE PRACTICES

Imerys Greece S.A. consists the Business Unit of Bentonite and Perlite Intermediates (BPI BU), part of the Metallurgy Division. Based on the 2018 CSR objectives set by BPI BU, individual measures are thereafter documented within the specific facilities and departments of Business Unit.

Based on the risk-based approach imposed by ISO 9001:2015 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology and integrated it with the BPI BU process approach. This risk management methodology helped identify not only risks, but also opportunities per process and facility and apply, among other, criteria and methods needed to ensure the effective operation and control of these processes, through key performance indicators (KPIs) set and monitoring. Process effectiveness is checked through KPI monitoring in order continual improvement to be achieved.

The Group’s Key Performance Indicators (KPIs) on Corporate Social Responsibility have been defined and gradually evolved in accordance with pertinent international Standards and regulatory framework. For additional information regarding Imerys KPIs results of three consecutive years (2016-2018), please refer to 2018 CSR Report (pp. 35-38).

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PERFORMANCE INDICATORS

The 2018 CSR objectives of BPI BU are depicted in the following table.

E = Environment incl. Energy                     H & S = Health & Safety           Q = Quality

BPI BU = Bentonite & Perlite Intermediates Business Unit

Take5 = “Take5” safety program is a pre-task risk assessment and reduction tool, which drives safety awareness to all employees, and is conducted both per employee (personal Take5) and per employees’ groups (Group Take5)

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4. Management of Value Chain

ADMINISTRATIVE PRACTICES

Imerys Greece S.A. follows specific processes for the selection and evaluation of providers and contractors. A relevant providers’/ contractors’ register is being kept and updated frequently. Based on that process, providers of critical materials and services have been recognized for Greece’s facilities, which are energy and soda (for bentonite activation).

Providers are separated in three categories: (1) minor, (2) moderate and (3) major/ critical based on the value of procurements per year. Specific criteria are set for the entry into the providers’ registry and for the evaluation of each provider, based on its categorization. Example of these criteria are, but are not limited to:

• Quality Management System (QMS) existence or application of quality assurance Standards;
• Environmental Management System (EMS) existence or application of environmental assurance Standards;
• Occupational Health and Safety Management System (OHSMS) existence and adherence to Health and Safety regulations;
• Safety and cleanliness of facilities;
• Adherence to Imerys protocols and fundamental safety rules.

All main (first tier) subcontractors have received Imerys ESG Standards. Alignment of Group contractors within Imerys Safety System (ISS) and safety cultural expectations is fundamental to achieve the Group safety goals. As such, the new Contractor Safety Management initiative, launched in 2017, outlines a common and systematic approach for the selection, monitoring and continuous improvement of the health and safety performance of contractors and sub-contractors.

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The Group expects its business partners and suppliers to adhere to the same principles as elaborated with the Group Code. As such in 2018, Imerys updated and launched new Supplier ESG Standards (the Standards). These Standards, are based on the Group Code and CSR Charter and are aligned with the SustainAgility program. The Standards, which must be formally acknowledged and complied with, are applicable to all suppliers and are considered a prerequisite for doing business with the Group, forming an important part of the Group Purchasing policy.

For additional information, please also refer to criterion 17: Human Rights in the supply chain.

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PERFORMANCE INDICATORS

• GRI 102-6 Disclosure: Markets served

Bentonite market

Imerys Greece S.A. is the largest bentonite producer in Greece, with significant mining activities in other countries (U.S.A., Germany, Bulgaria, Hungary, Morocco and Georgia). It is, in fact, the largest bentonite producer in Europe and the largest bentonite company in the world. In 2018, the largest volume of bentonite production was mainly exported to the European market and to North America (Canada).

Having a strong presence in international markets, bentonite is used in wide range of industrial applications and processes in the foundry and iron metallurgy market, in special applications (cat litter, papermaking), as well as in the construction industry, offering products and industrial solutions both in large infrastructure projects and in gas and oil drilling. During 2018, bentonite demand in foundry, which is interrelated with automotive market, had a slight upward trend. The same tendency appeared in other markets, such as iron, steel and civil engineering markets, while in oil and gas extraction markets there was a slightly downward trend.

Perlite Market

Imerys Greece S.A. is also the largest perlite producer in Greece, as well as the largest supplier of non-expanded perlite in the world. Perlite is widely used in building applications such as molded building materials (heat and sound insulation roof tiles and insulating filler materials) and provides industrial solutions to building materials, such as coatings, wall mortars and filtering media. Perlite is also used in cryogenic insulations, in agriculture, in foundries and as an improver additive in the production of phosphate fertilizers.

In North America, in 2018, sales of perlite regarding building applications and other specific applications had a significant increase, as oppose to sales regarding agricultural uses and cat litter, which had a slightly downward trend compared to 2017. In Europe, construction industry sales were slightly increased in 2018, whereas agricultural market sales remained stable compared to the previous year.

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5. Responsibility

ADMINISTRATIVE PRACTICES

The “go-to” reference source for all information about the Group’s internal control policies and procedures are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. SD (Sustainable Development) charters, policies and manuals, included in the Blue Book, mainly consist of the following documents:

Business Conduct

• Code of Business Conduct & Ethics
• Corporate Governance Policy
• Ethics Committee Charter

Health & Safety

• H & S Charter
• Injury and Health reporting protocol
• EHS Audit Policy

Environment

• Energy, emissions & production reporting protocol
• Environmental reporting protocol

CSR

• Corporate Social Responsibility Charter
• Diversity & Inclusion Charter
• Child Labour protocol

Moreover, all Imerys Greece S.A. employees - from top management and senior executives to shop floor employees and technicians - are informed during their hiring process regarding (1) Occupational risk assessment of their job position, (2) Safety Cardinal Rules and protocols, (3) EHSQ Policy, (4) Imerys Code of Business Conduct and Ethics and (5) Anti-fraud and anti-bribery policy, thus being informed about ESG topics. Top management and senior executives are actively engaged into implementing Group SD policies.

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PERFORMANCE INDICATORS

• GRI 102-19 Disclosure: Delegating authority

Imerys Greece S.A. has active participation to the following organizations:

Environmental and Sustainability Organizations

• SEV Business Council for Sustainable Development

Imerys Greece S.A. is a founding member of this organization. Mr. Athanasios Kefalas, General Manager Bentonite and Perlite Intermediates, is a board member.

• SEV Health & Safety Working Group

EHSQ and Supporting Services Manager, Mr. Yannis Karavelakis, is a member of the relevant working group.

Industry Organizations

• Industrial Minerals Associations for Europe (IMA-Europe)
• European Bentonite Association (EUBA) branch
• European Association of Mining Companies (Euromines)
• Greek Mining Enterprises Association (SME)

Imerys Greece S.A. is an enterprise – member of SME. Mr. Athanasios Kefalas, General Manager Bentonite and Perlite Intermediates is the president of Board of Directors, starting from 2017.

• SEV – Hellenic Federation of Enterprises
• Association of Industries & Exporting Enterprises of Milos

CSR Organizations

• CSR Europe
• CSR Hellas

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6. Rules & Processes

ADMINISTRATIVE PRACTICES

Imerys’ internal control policy is formally set out in the Code of Business Conduct and Ethics and the Corporate Governance policy, as well as in a number of charters (including the Board of Directors Charter, Corporate Social Responsibility Charter, Health & Safety Charter and Inclusion & Diversity Charter) that apply to the whole Group. Moreover, the Group’s policies developed by the central support departments (including Sales & Purchasing, Finance, Legal, Science & Technology and Information Systems) define the specific organization, responsibilities and operating and reporting principles for their respective areas of expertise. Lastly, the Group’s internal control manual defines the main internal control principles and the most important control activities to be carried out as part of the Group’s operating and financial processes.

The Group’s charters, policies and manuals are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. This fundamental set of rules forms the framework for the Group’s operations. It applies to all Imerys’ activities and the companies it controls. Certain communications are subject to electronic certification, through which employees must certify they have read the information and pledge to enforce the internal controls in their area of responsibility.

A second set of rules applies to the Group’s operations and defines their specific procedures and reporting principles. Procedures are adapted to each setup, approach to mining, industrial and commercial management and related risks, in line with Group policies. They take into account specific requirements set out in applicable local laws and regulations.

Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and BS OHSAS 18001:2007 Occupational Health and Safety Management System (OHSMS). Indicators connected with SD and CSR elements are also monitored in the context of the Integrated Management System (IMS). Imerys Greece S.A. follows a specific list of BU’s Procedures and local (GR) Instructions regarding quality, environment and health & safety issues, proving its compliance regarding the requirements of the 3 Standards that is externally certified for.

Based on the risk-based approach imposed by ISO 9001:2015 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology and integrated it with the BPI BU process approach. This risk management methodology includes, between others, KPIs set per business process, in order to address risks and opportunities. The KPIs set are monitored via a relevant KPI registry form.

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PERFORMANCE INDICATORS

• GRI 102-16 Disclosure: Values, principles, standards and norms of behavior

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The umbrella principles set forth in the Code are supported by a series of policies and protocols applying to both the general conduct of Imerys and the individual conduct of each employee. The subjects covered by the Code include compliance with laws and regulations, protection of environment and human rights, relations with local communities and trade unions, workplace safety and health, diversity and inclusion, confidentiality, prevention of fraud or corruption, prevention of insider trading and conflicts of interest, protection of the Group’s assets, fair competition, transparency, and integrity.

Imerys Greece S.A. facilities are included into an annual internal audit program. Internal audits are conducted according to its Integrated Management System (IMS), based on the status and importance of the processes and areas to be audited, as well as the results of previous audits. Audits are conducted by the use of generated checklists, procedures and interviews of personnel to determine compliance with quality, environmental, health & safety, customer, regulatory and other legal requirements. Internal audits are assigned to trained personnel (internal auditors), selected to ensure objectivity and impartibility of the audit process. Audit findings are communicated immediately, thus investigation, root causes found, corrective actions proposed and relevant action plan set should be in place. Audit findings are also reviewed at the management review meetings. Imerys Greece S.A. also utilizes outside consulting services to perform external audits in various auditing functions.

As defined EHS Auditing Procedure, Imerys conducts periodic audits of the Group's operating facilities to determine how well they comply with EHS laws and regulations and Imerys’ EHS protocols. Imerys’ EHS audits cover everything from internal Imerys protocols to local laws and regulations, expert verification for mineral solid storage facilities, and mine safety, which are covered by separate audits of the Group. Failure to comply results in an audit finding. These findings are rated with Red; if the risk attached to the failure is serious or very systemic, Orange; if the risk is important or somewhat systemic and Yellow; if the risk is less significant and isolated. Together with the plant management, an action plan for correcting any audit findings is established within 45 days. Completion of corrective actions is tracked in a dedicated database called MK Insight. Outstanding findings are regularly presented to the Executive Committee.

For Imerys SD charters, policies and manuals please refer to Criterion 5. For additional information regarding Imerys rules and procedures, please refer to 2018 Registration Document (p. 132).

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7. Monitoring

ADMINISTRATIVE PRACTICES

The Group’s Key Performance Indicators (KPIs) on Corporate Social Responsibility have been defined and gradually evolved in accordance with pertinent international Standards and regulatory framework, such as GRI’s Sustainability Reporting Guidelines (“Core” option), the UN Global Compact, the UN Guiding Principles on Business and, OECD Guidelines, International Organisation for Standardization (ISO) and the ILO Fundamental Conventions.

Imerys uses an intranet reporting tool entitled “Symphony”, through which safety data, environmental KPIs, environmental incidents, energy, CO₂ and production data are being reported every month and reviewed quarterly. Injury and health reporting protocol sets out the rules for inputting Safety data in Symphony and designates the individuals responsible for enforcing them. It explains the input, validation and checking recommendations for the KPIs in the reporting tool. Environmental reporting protocol and Energy, emissions & production reporting protocol address the reporting of corresponding information.

Imerys Greece S.A. facilities are certified with ISO 9001:2015 Quality Management System (QMS), ISO 14001:2015 Environmental Management System (EMS) and BS OHSAS 18001:2007 Occupational Health and Safety Management System (OHSMS). Indicators connected with SD and CSR elements are also monitored in the context of the Integrated Management System (IMS).

Based on the risk-based approach imposed by ISO 9001:2015 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology and integrated it with the BPI BU process approach. This risk management methodology includes, between others, KPIs set per business process, in order to address risks and opportunities. The KPIs set are monitored via a relevant KPI registry form.

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PERFORMANCE INDICATORS

A complete summary of the Group’s non-financial Key Performance Indicators (KPIs), which also reflect local performance at site level, can be found in 2018 CSR Report (pp. 35-38). The CSR strategy and reporting approach is based on GRI’s Sustainability Reporting Guidelines (“Core” option).

The GRI disclosures used for the completion of the 20 criteria of Greek Sustainability Code are summarised in the following GRI context index:

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8. Incentive and reward systems for Sustainable Development

ADMINISTRATIVE PRACTICES

Imerys Group compensation and benefits systems and policies aim at ensuring both market competitiveness and internal consistency, while being driven by a clear pay-for-performance objective. Fixed compensations are reviewed on a yearly basis under the close coordination of the Human Resources function, supported by regular local and/or sectorial surveys, and conducted with strict financial discipline.

Short-term variable pay schemes include both individual and collective objectives, in order to reward both personal and financial collective performance. All top management and senior executives should include not only financial, but also health and safety objectives in their annual objectives. Achievement of the objectives is measured and observed annually by the upper tier employee. All Imerys employees are encouraged to include in their personal objectives issues dealing with sustainable development, such as health & safety, environment, human resources development etc. The weigh factor of each objective depends on the area of expertise of every employee. Long-term compensation programs, based on Performance Shares, are fully aligned on the Group long term financial objectives. The Group endeavors to align its remuneration practices across the best international Standards.

Job descriptions issued by Imerys Greece S.A. Human Resources departments for executives’ job positions are descriptive of the relevant EHS responsibilities that newly hired and older executives should follow. Moreover, all employees in Imerys Greece S.A. facilities are encouraged to participate voluntarily in corporate CSR actions, internal and external health and safety trainings, environmental initiatives and initiatives of the organizations company is an active member (environmental and sustainability, industry and CSR organizations).

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PERFORMANCE INDICATORS

• GRI 102-35 Disclosure: Remuneration policies

For more information on the Group Executive Remuneration, see chapter 3, section 3.3 of the 2018 Registration Document.

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9. Stakeholder Engagement

ADMINISTRATIVE PRACTICES

The Group depends on the solid long-term relationships it develops with its key stakeholders; respecting the countries, communities and environments across the globe where its operations are located. As such Imerys considers itself accountable to a wide variety of stakeholders, both internal and external. Identifying stakeholders and gaining an understanding of their needs and expectations is a critical step to foster engagement.

In 2017, in the context of the definition of the Group’s CSR program, Imerys launched a materiality assessment process in order to further integrate stakeholder expectations on Environmental Social and Governance (ESG) risks, threats and opportunities facing the Group within the definition of material CSR priorities. This process can be summarized in three phases:

(1) Framing; focused on the research and analysis required to identify and verify a long list of potentially significant ESG issues,

(2) Engagement; engagement with both internal and external stakeholders through broadened and deepened consultation on the CSR themes, and

(3) Analysis and validation; resulting in confirmation of the continuous focus on the priority CSR themes identified in 2017 and preliminary actions to be taken.

For additional information regarding Group’s stakeholder engagement, please refer to 2018 CSR Report (p. 4).

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PERFORMANCE INDICATORS

• GRI 102-40 Disclosure: List of stakeholder groups
• GRI 102-43 Disclosure: Approach to stakeholder engagement

The list of stakeholders groups with whom Imerys engages in various capacities across the globe includes: banks & brokers, business partners, competitor and peer companies, customers, employees, government authorities, local community members, media, non-governmental organizations, professional associations, shareholders and investors, and suppliers and subcontractors.

Based on the risk-based approach imposed by ISO 9001:2015 and ISO 14001:2015 Standards, Imerys Greece S.A. established a systematic and consistent methodology and integrated it with the BPI BU process approach. This risk management methodology helped, between others, the identification of interested parties/ stakeholders and the identification of their needs and expectations. These interested parties were also correlated with Imerys Greece S.A. business processes.

Imerys Greece S.A. stakeholder groups and their specific engagement methods are:

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10. Product Responsibility and Innovation

ADMINISTRATIVE PRACTICES

Imerys is committed to providing high-quality products to its customers, and indirectly, to end-users through sound, responsible product management. The Group’s commitment to sustainable product management and the development of technologies is a means to contribute to SDG 12 to ensure sustainable consumption and production patterns and to SDG 13 to take urgent action to combat climate change and its impacts. Imerys’ overarching goal is to identify and minimize the health, safety, environmental, and social impacts of all of Group products throughout their lifecycle, while maximizing their economic benefits and positive impacts to customers and their end consumers. Imerys is committed to the quality and safety of its products, which are assured through dedicated product stewardship programs.

The Group employs state-of-the art analytical methods, equipment, and testing to ensure that product assessments and associated decisions are driven first and foremost by sound science. The Group continually evaluates testing protocols and invests in innovation in health, safety, and sustainability across product ranges, locations, and production processes. These measures enable the Group to produce high-quality products, meet customers’ expectations and operate in a stringent, dynamic regulatory environment.

For certain minerals, the Group applies the Mine to Market Mineral Management (M4) program, both for owned and external deposits. For products manufactured in (or imported into) Europe, the Group complies with the European Directive on “Regulation, Evaluation and Authorization of Chemicals” (REACH). Substances marketed by Imerys are frequently subject to risk studies to determine their properties (e.g., pursuant to the GHS/CLP Regulations in Europe). Imerys monitors these studies closely, and labels its products to appropriately reflect the results of these studies.

To remain competitive, maintain organic growth and increase profitability, the Group has placed organizational, technological and commercial innovation at the heart of its strategy. It is also an effective way for the Group to tackle the sustainable development concerns related to its operations.

In 2018, the Group developed a new Group product stewardship policy and supporting protocols, which defined the objectives, roles and responsibilities, guiding principles and specific requirements, as well as continuous improvement process to be followed. In 2018, Imerys also assessed the various methodologies available to assess product sustainability and prepared for the launch of an assessment tool in line with the World Business Council for Sustainable Development (WBCSD) framework for Portfolio Sustainability Assessments (PSA), so as to objectively measure the sustainability of Imerys products and identify their environmental and social impacts.

Imerys Technology Centre (ITC) of Greece, as part of the Innovation department, facilitates internal synergies and contribute to sharing best practices and assist in the development of shared and cross-disciplinary projects involving the Group’s scientific experts. Imerys commitment to developing tomorrow’s innovations also involves forming close long-term partnerships with renowned universities, research institutes and international organizations, thus ITC Greece have signed partnership agreement with the National Technical University of Athens (NTUA) for innovative projects.

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PERFORMANCE INDICATORS

• GRI 302-4 Disclosure: Reduction of energy consumption

Imerys 2018 objective was to improve the Group energy efficiency by 2% relative to 2017 by the end of 2018. Imerys Greece S.A. went over and above the Group’s target and set energy efficiency improvement at 3%, assigning specific programs per facility (please refer to criterion 3 for full list of 2018 BPI BU CSR Objectives).

In Milos facilities, FLU-ACE condensing flue gas economizer project in Tsigrado plant was launched mid-2015 and after almost two years of research and development (R & D) studies and preparations, it was first implemented on May 2017. The system is an exclusively in-house project development and is considered an Imerys proprietary process. In 2017, 4 people have been occupied with the projects implementation and 400 hours have been spent, while the cost is estimated to approximately 208,000€. Net present value from the system’s operation is 124,000€ (depending on current oil prices). Target audience of this project is the local community and environment of Milos island.

The project’s goal is two-fold (1) to reduce energy (heavy fuel oil) consumption by an average of 6-7% (also reducing CO₂ emissions by 600 t/year), and (2) to produce 0,8 M³/hour water for industrial use. Specific numbers have as follows:

• An average of 310 kW of heat is recovered from the exhaust gases of the Tsigrado dryer.
• Around 0.8 M³/hour water for industrial purposes is produced by cooling the flue gas from approximately 70-80°C down to 40° The total production of water for 4,500 hours of operation is 3,600 M³.

As the system seems to be working very well, and with the expected positive outcome for Milos island environment, two more FLU-ACE condensing flue gas economizers are planning to be installed in Milos facilities (Voudia perlite plant), during 2018 - 2019.

In Milos facilities, 3% energy efficiency improvement relative to that of 2017 was also achieved by the operation of a new filter and new fan in the Old Unit of Bentonite Drying Plant, which affected electricity consumption, as well as dust emissions. Moreover, within the timeframe of 2018 – 2020, new land acquisition will increase natural drying capacity and reduce the incoming water load to the dryers, which will consequently decrease the fuel oil requirements and electrical energy consumption.

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11. Usage of Natural Resources

ADMINISTRATIVE PRACTICES

Imerys is committed to act as responsible environmental stewards. By efficiently exploiting the resources at its disposal and creating positive biodiversity value in the long term, Imerys is committed to SDG 12 to ensure sustainable consumption and production patterns and SDG 15 to protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, and halt and reverse land degradation and halt biodiversity loss.

Environmental management

Environmental stewardship rests upon the implementation of a robust Environmental Management Systems (EMS), which is a key factor to improve operating efficiency while reducing environmental impacts. Imerys requires each operation to have an effective EMS enabling it to identify and establish controls for significant environmental risks. The mandatory EMS requirements for all activities are covered by Group-wide environmental protocols, which include eight pillars aligned to the core elements of the international Standards for environmental management systems: policy, aspects and impacts, legislative and regulatory requirements, objectives and targets, roles and responsibilities, training, emergency response, and auditing.

In addition to implementation of mandatory EMS requirements, the Group encourages ISO 14001 and Eco-Management and Audit Scheme (EMAS) certifications. As of the end of 2018, all Imerys Greece S.A. operations were ISO 14001 by external certification organization.

In 2018 the Group began the testing and pilot roll-out of a new integrated solution to manage environmental legal compliance and regulatory monitoring in 4 countries. This new solution supports the development of updated environmental legal registers, with regular alerts, register updates and regulatory assistance by environmental legal specialists for each country. This solution will be progressively tested and deployed in several geographic areas to support continuous improvement and is planned to be initiated for Imerys Greece S.A. facilities during 2019.

Non-energetic resources efficiency

The technological know-how of Imerys, as a world leader in industrial minerals, enables the Group to be in an excellent position to improve the yield on materials of its operations. At the same time, the strength of the Group’s commercial network and strong innovation capacity maximize Group production value and capacity to optimize resource use efficiency across the globe, thereby contributing to SDG 12 to ensure sustainable consumption and production patterns.

Biodiversity and rehabilitation

The question of impacts on the living world arises during the entire life cycle of a quarry, whether for the choice of the site, its operation or its rehabilitation. Aware of this responsibility, Imerys has been committed to preserving biodiversity for many years. Given the serious global threat to biodiversity, Imerys is committed to further structure and harmonize its approach, in order to continue mobilizing the Group and its teams around this major issue. Imerys has designed and implemented a biodiversity project, aligned with the main goals of the French National Biodiversity Strategy, to continue to contribute to SDG 15 to protect, restore and promote sustainable use of terrestrial ecosystems, sustainably manage forests, combat desertification, halt and reverse land degradation and halt biodiversity loss.

Rehabilitation is integrated into the Life of Mine (LOM) plan of each quarry operation at Imerys and considered throughout the conduct of its activity until closure. The Group has a specific protocol outlining the requirements related to rehabilitation. Rehabilitation planning starts from the very initial phase of mine permitting as it is included in the environmental impact assessment of the projected site operations. As most countries define the regulatory framework for the preparation, submission, consultation and approval of environmental impact assessments for resource operational permits, in most cases rehabilitation plans are disclosed through a public consultation process prior to final approval.

All Imerys Greece S.A. facilities are certified with ISO 14001:2015 Environmental Management System. Based on the Life Cycle Perspective (LCP) imposed by ISO 14001:2015 Standard, Imerys Greece S.A. has mapped the life cycle stages that can be controlled or influenced by its facilities. Life cycle stages applicable vary depending on the activity, product or service, while LCP does not require a detailed life cycle assessment. Through this, the way company's products and services are designed, manufactured, distributed, consumed and disposed is controlled or influenced, by using a perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle.

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PERFORMANCE INDICATORS

• GRI 301-1 Disclosure: Materials used by weight or volume

In 2018 Imerys Greece S.A. mined 1,340,092 MT of bentonite, 743,359 MT from Aggeria mine, 471,537 MT from Agia Irini mine, 85,603 MT from Aspro Chorio and 39,593 MT from Zoulias mine. It also mined 319,968 MT of perlite, 198,837 MT from Tsigrado mine and 121,131 from Trachilas mine. 36,671 MT of sodium carbonate (Na₂CO₃) were also used in 2018 for bentonite activation.

• GRI 302-1 Disclosure: Energy consumption within the organization

Imerys has operational energy demand, especially in its mineral transformation processes that use thermal technologies and its quarrying activities that use heavy equipment. Energy efficiency improvement makes it possible to use less energy to achieve the same level of productivity and consequently to contribute to climate change mitigation efforts. The Group energy efficiency strategy is based on two pillars: efficiency, which consists of measuring, decreasing consumption, and recovering energy losses, and sourcing, which is based on using alternative energies, promoting renewables, and building sustainable industrial assets. Imerys is improving energy management and driving excellence through the Group “I-Cube” Program (a program designed to continuously improve its industrial processes and performance entitled Imerys Industrial Improvement). In 2018, the program was rolled out to 175 Group sites in total, within which the site of Milos is included.

The energy consumption per energy source in Milos facilities and Athens office premises, for 2018, is depicted in the following tables:

• GRI 306-2 Disclosure: Waste by type and disposal method

Imerys processes minerals using methods that are primarily mechanical and physical. As such the Group’s activities generate relatively small quantities of domestic and industrial wastes. The Group is nevertheless committed to reduce waste generation through prevention, reduction, recycling and reuse as a means to contribute further to SDG 12 on sustainable consumption and production patterns. Overburden and unused mineral solids are usually stored on or near production areas at the quarries given their potential to be valorised in the future. Overburden and unused minerals are also used in many cases as backfilling or re-profiling materials in post-mining restoration work. As such, this material is not classified as waste.

Total waste quantity per facility and per European waste code (type of waste) is depicted in the following table. All waste are managed outside Imerys Greece S.A. facilities by certified waste companies. Waste disposal inside Milos facilities refers only to preliminary storage. Production of waste is reported per quarter. Herein total waste quantities are depicted for the year 2018.

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12. Resource Management

ADMINISTRATIVE PRACTICES

Imerys is committed to assess relevant environmental risks and continually improve control measures to reduce adverse environmental impacts, maximizing the efficient use of natural resources and conserving and creating biodiversity value.

Establishing and maintaining effective management of mineral resources is a priority for the Group. Mineral resources management is defined through a series of geology and mine planning policies, procedures and protocols. Each mining operation is required to have a Life of Mine Plan (LOM Plan) and create a detailed Five-Year Mine Plan. This approach enables the operations to maximize the efficient use of mineral resources. Opportunities to optimize mineral resource consumption are identified continuously during the implementation process of the “I-Cube” program and through other ongoing initiatives, including the Group SD Challenge.

Imerys aims to minimize the impact of its operations on water resources. The Group is committed to ensure effective management of water resources by focusing on optimizing water consumption by limiting withdrawal from natural environment and developing recycling possibilities for process water. Imerys classifies water withdrawals according to source, including groundwater, surface water and water from suppliers. Water moved from one zone to another without being used (water pumped for quarrying operations) is not quantified within this metric as the quality of this water is not altered. Imerys also reports the amount of water recycled by its operations as recycling water reduces the amount of water being removed from natural habitats, thereby reducing the Group water footprint. The Group is working towards the identification of innovative ways to reduce its water footprint.

Please refer to Criterion 11 for additional information regarding materials used by weight or volume (GRI Disclosure 301-1), energy consumption within the organization (GRI Disclosure 302-1) and waste by type and disposal method (GRI Disclosure 306-2).

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PERFORMANCE INDICATORS

• GRI 303-1 Disclosure: Water withdrawal by source
• GRI 303-3 Disclosure: Water recycled and reused

The total volume of water withdrawn by Milos facilities in 2018 is given with a breakdown in municipal water supplies, ground water and surface water. The amount of water recycled is also being reported, as recycling water reduces the amount of water being removed from natural habitats, thereby reducing Imerys water footprint. The consumption of water is reported quarterly. It has to be noted that surface water category refers to sea water used in scrubbers.

The water consumption in Athens office premises, for 2018, has as follows:

Attached Files: There are no files

13. Climate-relevant emissions

ADMINISTRATIVE PRACTICES

Imerys is committed to reduce the impacts of climate change through the implementation of a long-term climate change strategy to support international commitments and global targets.

Imerys recognizes that climate change is a major global challenge. In 2017, on the occasion of the international One Planet Summit, the Group became signatory of the French Business Climate Pledge. Through this Pledge, Imerys publicly affirms its engagement to contribute to the collective efforts and work towards SDG 13 to take urgent action to combat climate change and its impacts. As such Imerys has pledged to define its Climate Change strategy aligning its emission targets and trajectory to a 2°C scenario. In September 2018, the Group committed to set its targets through the Science Based Targets initiative (SBTi) within the next 24 months.

Since the end of 2017, the Group’s climate change working group, composed of environmental, energy, industrial, business development as well as financial managers, has been working to address climate change as a priority CSR theme. The cross-functional working group has completed a comprehensive climate change benchmark, assessed risks and opportunities as well as current CO2 footprint of the Group, defined relevant KPI and targets, and began to identify concrete levers for carbon reduction in the context of the long-term climate change strategy. The defined strategy will ultimately cover every domain: organization, equipment, methods, technology, supplies, transportation, and renewable energies. The Group has defined its Scope 1 and 2 emissions objectives and will define Scope 3 emissions objectives in 2019.

The majority of the Group Green House Gas (GHG) emissions are generated through in the production of thermal energy from natural gas, fossil fuel, biomass and steam. Indirect emissions from the consumption of electricity are the second source emissions. Measures to monitor and reduce the GHG emissions are one of the principal means through which the Group contributes towards SDG 13 to take urgent action to combat climate change and its impacts.

For the past 11 years, Imerys has participated in the climate change program of the Carbon Disclosure Project (CDP). As of the end of 2018 the Group CDP performance score is ranked as Level C.

Imerys Greece S.A. facilities have set as energy efficiency target for 2018, 3% improvement on the 2017 baseline by the end of the year. Specific programs have been assigned in Milos facilities as the operation of a new filter and new fan in the Old Unit of Bentonite Drying Plant, which affected electricity consumption, as well as dust emissions. Moreover, within the timeframe of 2018 – 2020, new land acquisition will increase natural drying capacity and reduce the incoming water load to the dryers, which will consequently decrease the fuel oil requirements and electrical energy consumption.

Attached Files: There are no files

PERFORMANCE INDICATORS

• GRI 305-1 Disclosure: Direct (Scope 1) GHG emissions

Scope 1 emissions are direct emissions from sources owned or controlled by Imerys. Imerys Greece S.A. facilities in Milos do not produce direct (Scope 1) GHG emissions. This derives from the fact that the facility in Greece with existing gas emissions limits is an electricity generator located in Voudia, Milos. However, this generator operates only when a multi-hour power outage from PPC S.A. (Public Power Corporation S.A. – Hellas) exists. In 2018, the electric generator was not set in operation.

Moreover, all facilities have their own approved environmental terms which abide by Greek Legislation concerning dust and smoke emitted by chimneys (Presidential Decree 1180/1981). Dust or solids in suspension, which affect the wider environment around plants through operations like transportation of bulk products and storage, do not exceed 150 mg/m³ in old plants and 100 mg/m³ in new plants or any specific limit given in approved environmental terms. Smoke does not exceed level 1 of Ringelmann scale, which is a scale for measuring the apparent density of smoke by observing the plume generated at the point of greatest opacity.

• GRI 305-2 Disclosure: Energy indirect (Scope 2) GHG emissions

Scope 2 emissions are indirect emissions from the generation of purchased energy. Every year about 1,000,000 MT of bentonite are mined on Milos Island and almost all of that quantity has to be dried to 15% on average. Significant energy saving is achieved by exploiting Milos island climatic conditions - high temperature and wind during summer - for the natural pre-drying of bentonite in open fields. This results in approximately 35% annual energy savings, compared to the energy that would be required if industrial drying was exclusively used. It is estimated that some 100,000 MT of water are evaporated on a yearly basis through this field drying process. This is equivalent to actual savings of about 7,500 MT of annual heavy fuel oil consumption, corresponding to CO₂ emissions reduction in the range of 24,000 MT per annum.

For additional information regarding Group’s carbon emission management, please refer to 2018 CSR Report (p. 26)

• GRI 305-7 Disclosure: Nitrogen oxides (NO_x), sulfur oxides (SO_x), and other significant air emissions

In order to progressively quantify the impacts along the Group value chain, the Group is increasing the attention it pays to the estimation and management of Scope 3 emissions.

Imerys Greece S.A. does not produce direct NO_x and SO₂ emissions. This derives from the fact that the facility in Greece with existing NO_x and SO₂ gas emissions limits is an electricity generator located in Voudia, Milos, which uses crude oil with low sulfur content. However, this generator operates only when a multi-hour power outage from PPC S.A. (Public Power Corporation S.A. – Hellas) exists. In 2018 the electric generator was not set in operation.

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14. Employment Rights

ADMINISTRATIVE PRACTICES

Imerys strives to promote mutual respect in all practices and dealings with its employees, and outside contractors. Imerys recognizes that management of relations with employees is critical to the creation of an environment in which all employees can excel. The Group is committed to respect and promote the International Bill of Human Rights and provisions of the fundamental conventions of the ILO and to comply with local legislation in force in the countries where it operates, particularly in terms of non-discrimination, privacy, child labor, compensation and working hours. Imerys endeavors to have a positive impact through its employment practices upon the welfare of employees, which likewise has both indirect and induced positive impacts also on surrounding communities and thereby contribute to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

In 2018 the Group released a new Group Code of Business Conduct and Ethics that spells out the fundamental principles and shared commitments to ethical behavior including respect of human rights and labor practices. The Code, applies to all Imerys employees, including those of its subsidiaries, as well as those who do business with Imerys. Managers at Imerys have a particular responsibility to ensure its daily application because of their roles and responsibilities with regards to Group operations. Imerys recognizes the right to freedom of association and the right to collective bargaining, which is clearly articulated within the new Code as well as within the Group Employee Engagement Policy. At the end of 2018, approximately 68% of employees were covered by Collective Bargaining Agreements (CBAs). These CBAs commonly include subjects such as health and safety, work organization and working hours, training, compensation and benefits, and equal opportunities.

Imerys is fully committed to taking effective measures to end discrimination and to eradicate child labor and forced labor. Compliance with the Code and protocols on human rights and labor practices, including preventing child labor and forced labor, is included within due diligence assessment for new projects and within the scope of internal auditing missions for the Group existing activities. Protocols on prohibition of child labor and forced labor have been in place since 2009.

In April of 2017, Imerys launched its first global employee engagement survey “Your Voice”. This survey was conducted confidentially and anonymously offering employees the opportunity to express their position on a wide range of topics. The results of the survey showed high levels of engagement and enablement across the Group, driven by a strong loyalty to Imerys. The outcomes of this survey were presented across the Group, with focusing on global action plans as well as local results and action plans. At the global level, dedicated teams with clear owners were identified to drive the development and implementation of improvement plans related to diversity and inclusion, Group processes, strategy and internal communication. Throughout 2018, the dedicated teams worked on the action plans and communicated on their progress. The outcome of this employee engagement survey has been integrated into the materiality assessment to contribute to the identification of material CSR risks and definition of Group CSR priorities.

The need to improve the efficiency of Group activities may lead to internal restructuring plans and job cuts. In such situations, the Group’s policy is to give priority to finding in-house placement solutions for concerned employees and to set up retraining programs and support measures to help them find a job or carry out a personal project.

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PERFORMANCE INDICATORS

• GRI 404-1 Disclosure: Average hours of training per year per employee

Targets regarding health and safety training per employee have been met for 2018. Training target for Imerys shop floor employees was set to 12h/ year/ employee, while for office employees the same target was set to 1h/ year/ employee. Indicative training courses carried out during the year were:

• Safety Connect Day

Safety Connect Day (SCD) in 2018 was a full working day dedicated to safety and took place on 22.06.2018. The theme for the second annual SCD was “My personal commitment to safety” that was relevant to everyone throughout Imerys Group, irrespective of location. During SCD all Imerys sites around the world were urged to make safety pledges, aiming to make sure that all employees are responsible for their own safety and that of others. During the event, employees in Milos and Athens facilities participated in a diverse range of interactive activities, trainings, seminars, working groups and sessions regarding safety.  Overall, annual Safety Connect Day provides an occasion for employees to consider how their individual and collective behavior can create an even safer Imerys.

• “Serious Seven” awareness and training campaign

The “Serious Seven” safety compliance program governs safety in the critical areas of Lockout/Tagout/Tryout (LOTOTO), electrical safety, machine guarding and conveyor safety, mobile equipment, working at heights, ground control and forklift safety. This campaign was launched in 2018 and was mandatory for all Imerys employees.

• Slips, Trips and Falls (STFs) prevention campaign

A new Imerys campaign of Imerys in order to improve Group’s safety performance and to eliminate incidents associated with STFs. This campaign was organized through an assessment of the workplace, enabling sites to set up action plans and measure improvements, as well as raising employees’ awareness on these risks.

• Fire protection training, targeted to all employees and not only fire protection teams;
• First aid training, targeted to all employees and not only Samaritan teams;
• Dust masks fit testing for laboratory employees.

Based on the above-mentioned, commitment to continuous training is clearly identified. All Imerys employees are informed regarding health and safety issues, with specific and targeted training interventions, informative sessions on relevant corporate Standards and customized sessions based on specific risks identified.

Training of Imerys Greece S.A. employees for 2018 (total number of 309) per thematic category and cost are depicted in the attached charts.

• GRI 405-1 Disclosure: Diversity of governance bodies and employees

Imerys Greece S.A. had a total number of 309 employees in 2018. The distribution of employees according to their gender, hierarchical scale, years of employment, age group and facility they are operating is depicted in the attached charts.

Attached Files: Download EmployeeDistribution2018_AgeGroup Download EmployeeDistribution2018_Facility Download EmployeeDistribution2018_Gender Download EmployeeDistribution2018_HierarchicalScale Download EmployeeDistribution2018_YearsOfEmpoyment Download Training2018_Cost Download Training2018_ThematicCategory

15. Equal Opportunities

ADMINISTRATIVE PRACTICES

Imerys human capital is the most important Group asset, thus ensuring the respect of human rights and labor practices, developing tools for talent and skills management, maintaining constructive social dialogue and ensuring a diverse and inclusive environment with equal opportunities for all are crucial to the Group long-term strategy. The threats in this regards are related to potential violations of the Group Code of Conduct and Business Ethics that could result in potential risk of salient right abuses. While not assessed as a material risk at Group level, the promotion of diversity and inclusion is considered to be a long-term objective that needs constant focus as expressed through the employee engagement survey and as such the development of the Group program shall continue to be a high priority throughout 2019.

Safety and health are core values for all Imerys operations worldwide. The Group is committed to developing a proactive safety and health culture through partnerships among management, employees, contractors, suppliers, visitors and the communities in which it operates. The Group is likewise committed to continuous improvement cycle of safety and health performance, setting objectives and monitoring, reporting, auditing and reviewing. The personal involvement of each individual within Imerys is considered essential to achieving an incident-free workplace. This safety and health framework is fundamental to the Group's success and contributes to SDG 3 to ensure healthy lives and promote well-being for all at all ages and concrete contributes to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

The Group strives to build constructive, open dialogue with its employees and their representatives in accordance with local regulations and implements best practices in matters of workforce management. Establishing and maintaining this open dialogue is a means to contribute to SDG 10 to reduce inequality within and among countries.

Internal communication campaigns aim to provide all employees with information that can help them understand the Group’s strategy, environment and activities, build their sense of belonging and highlight the Group’s values to help strengthen its identity. In 2018, Imerys launched a new Group news and collaborative social platform that supports daily communication and collaborative needs and simplifies how Imerys’ employee connect and work together. This new platform hosts essential information, documentation and protocols, but also social feeds and workspaces, tools and business applications. The new intranet is optimized to enable employees to use tools and resources in a more agile way – including smartphone access to Group level applications. The new intranet facilitates the sharing of projects, initiatives and successes throughout the Group. It is likewise a platform to share information and support discussion on specific topics within specialized communities.

The Group is also committed to promote a culture based on mutual respect and appreciation, where the value and contribution of each individual is welcomed and recognized. Imerys does not tolerate any discrimination and/or harassment of its employees, contractors, customers, suppliers or other stakeholder on the basis of gender, age, nationality, citizenship, ethnicity, religion, background, sexual orientation, disabilities, marital and parental status, or political affiliation. The Group recognizes that diversity and inclusion are long-term ambitions and while the Group has not yet reached its full ambition, it is fully committed to its accelerate efforts and as such contribute further to SDG 5 to achieve gender equality and empower all women and girls and SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

The Group’s Diversity and Inclusion Charter, which was updated in 2018, clearly articulate the shared commitment to achieving greater diversity, as well as inclusion across the Group. In 2017, the Group identified diversity and inclusion as a priority CSR theme for 2018 and launched a diversity and inclusion working group composed of representatives of different businesses and functions across the Group. The purpose of this working group, whose mandate continued throughout all of 2018, was to conduct research and analysis on diversity and inclusion across the Group, to identify key drivers and challenges and propose concrete practices, including the necessary monitoring and review, to accelerate progress. Through the involvement of Executive Committee members and General Managers as sponsors, and with the support of two external Diversity and Inclusion experts, the working group has structured the fundamental elements of the program, with specific actions launched in 2018 and the full program that will begin to be rolled out in 2019. The program status and action plan was presented to the Board Nomination Committee in November 2018, with a restitution to the Board in early 2019.

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PERFORMANCE INDICATORS

• GRI 403-2 Disclosure: Types of injury and rates of injury, occupational diseases, lost days, and absenteeism, and number of work-related fatalities

The Group has an internal safety and health incident reporting process and associated database. Incident investigations are conducted and corrective actions are implemented at site level with follow-up at division level. Safety Alerts are issued whenever a Lost-Time Accident occurs to share root causes and lessons learned. Where appropriate, corrective actions identified through an incident investigation are directly integrated into the next update of Group safety protocols to reduce the risk of recurrence. In 2018, approximately 59 safety alerts were delivered by the Group.

Imerys tracks and analyses safety performance for both employees and contractors on a monthly basis using indicators for fatalities, life-changing injuries, lost-time and non-lost-time accidents at the Group level. All levels of the Group review recorded safety performance metrics every month. The progress on all the aforementioned key objectives and programs is reviewed quarterly. The Group is preparing for the deployment of a new tool to strengthen the management of incidents and introduce new leading inicators, such as inspections and site visit reports with KPI reporting and follow-up.

To prevent workplace-related illnesses and accidents, Imerys Greece S.A. facilities are certified with BS OHSAS 18001:2007 Occupational Health and Safety Management System (OHSMS). Imerys Greece S.A. operations also participate in the European Social Dialogue Agreement (SDA) on workers’ health protection through the good handling and use of crystalline silica and products containing it and have reported on specific aspects of their implementation through participation in a program organized by the European Network for Silica (NEPSI)*.

In 2018 there were 0 fatalities or life-changing injuries, 0 Lost Time Accidents (LTA), 1 Non Lost Time Accidents (Non-LTA) without light duty, 10 first aid accidents, 0 near miss with big impact (which could have been a life-changing accident or fatality), 26 near miss incidents and 341 conditions reported on Imerys incidents’ database for Imerys Greece S.A. In all incidents relevant corrective actions were taken in order for similar incidents to be prevented.

LTA and non-LTA rates per million hours worked for Imerys Greece S.A. in 2018 are depicted in the attached diagram.

Health surveillance of workers is in compliance with Greek legislation in each facility. In all facilities, workers are given the possibility to obtain external general and specialized medical testing. In Milos facilities, audiometric and spirometry tests are carried out by the occupational physician periodically. There are also performed regularly measurement regarding noise, dust and vibrations from vehicles – equipment to all relating employees. Harmful factors’ measurements are also conducted within the office premises for office employees.

• GRI 403-4 Disclosure: Health and safety topics covered in formal agreements with trade unions

Each Imerys contractor during its work is required to provide not only compliance with Health & Safety requirements of the Greek Legislation, but also compliance with Imerys safety procedures and protocols. Specifically each contractor should:

• Comply with Imerys “Safety Cardinal Rules”
• Comply with “Serious Seven” Safety Protocols
• Report any safety incident so as for the necessary corrective measures to be taken
• Submit a written risk assessment, taking into consideration all described safety measures and practices

Alignment of contractors within Imerys Safety System (ISS) and safety cultural expectations is fundamental to achieve the Group safety goals. As such, the new Contractor Safety Management initiative, launched in 2017, outlines a common and systematic approach for the selection, monitoring and continuous improvement of the health and safety performance of contractors and sub-contractors.

Imerys Code of Business Conduct and Ethics (the Code) summarizes the principles of ethical behavior the Group expects from all of its employees, contractors, suppliers, and other partners. The umbrella principles set forth in the Code are supported by a series of policies and protocols applying to both the general conduct of Imerys and the individual conduct of each employee. The subjects covered by the Code include compliance with laws and regulations, protection of environment and human rights, relations with local communities and trade unions, workplace safety and health, diversity and inclusion, confidentiality, prevention of fraud or corruption, prevention of insider trading and conflicts of interest, protection of the Group’s assets, fair competition, transparency, and integrity.

The same targets regarding health and safety trainings which have been met for 2018 for Imerys employees, apply also for contractors’ employees. Training target for contractors’ shop floor employees was set to 12h/ year/ employee, while for contractors’ office employees the same target was set to 1h/ year/ employee

• GRI 404-1 Disclosure: Average hours of training per year per employee

The relevant disclosure is mentioned within Criterion 14.

• GRI 406-1 Disclosure: Incidents of discrimination and corrective actions taken

No incident of discrimination took place in 2018 at Imerys Greece S.A. facilities, thus there are not any incidents report and relevant corrective actions.

Attached Files: Download LTA and non-LTA rates

16. Qualifications

ADMINISTRATIVE PRACTICES

Human capital is at the heart of Imerys’ business. Imerys seeks to create an environment that promotes employees development as a key element of growth and transformation. As such the Group HR policies and practices are based on fairness, openness and mutual respect. The long-term objectives of the Group are to identify, attract, select and retain talented people; develop and provide essential competencies; share ideas, projects, best practices across the organization; and ensure transparency and compliance with both legal requirements and Imerys’ policies and regulations. Through constant engagement on these subjects the Group contributes to SDG 5 to achieve gender equality and empower all women and girls; and to SDG 8 to promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

Talent and skill management is essential to maintain an innovative, engaged and motivated workforce and to ensure strong long-term growth within the Group. The Group talent road map continues to improve Human Resources processes focusing on recruitment, employer branding, internal mobility, professional learning, development and retention. All of these processes contribute to the development of human capital in Imerys and thus work towards SDG 4 to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all.

Supporting internal evolution and career moves across the Group is a priority. Imerys is committed to ensure its employees’ development and specialized committees meet regularly to discuss internal mobility and promotions. Imerys continues to attract new and highly experienced managers, and likewise continues to focus on developing the Group managers of the future.

Imerys Leadership Behaviors, which were rolled out in 2016 and have become an integral part of the entire talent management cycle, including recruitment, onboarding, performance and potential assessment, development and succession plans. In order to develop leadership and managerial skills, annual reviews are now composed of a shared evaluation between employees and their line managers based on these principles.

To ensure that Imerys not only attracts the right people for the right positions, but also that the process generates a positive candidate experience, and facilitates the integration within Imerys, the Group has designed a global recruitment policy, which will be rolled-out from 2019. This policy addresses five stages in the recruitment process: preparation, sourcing, selection, decision and onboarding.

A global onboarding program was designed and deployed in 2018 and includes a clear process based on best practices from across the Group but also learning paths that give each newly recruited employee clear knowledge about Imerys. The onboarding program toolbox contains valuable information on the global process, induction planning, new hiring orientation survey, a welcome pack, etc. This onboarding is supported by a dedicated workflow within the Group HR data platform that ensures that all new employees receive key messages and information directly after arrival. In addition to the above, a global internal mobility policy was defined in 2018 to provide a streamlined process to develop employees by exposing them to new challenges and new businesses within Imerys; to respond to employees’ aspirations to evolve; to facilitate the collaboration between all businesses; and contribute to reinforce the Group culture and mindset.

Imerys is fully committed to education and in particular to the fight against illiteracy, the education of women and girls and the support of young adults to enhance their employability. Since 2017, Imerys has had a specific objective to create an education program, contributing to SDG 4 to ensure inclusive and equitable quality education and promote lifelong learning opportunities for all. The Group launched internal communication using various medium to share information on its commitment towards literacy and numeracy.

The Group is committed to continuously diversify and increase Group’s training program through a blended learning approach, enabling employees to actively lead their own development and learning experience. The Group e-learning platform “IM-Pulse” hosts Imerys’ entire training offer. In 2018, the Group launched a major Safety training campaign to raise awareness and enhance knowledge about the Group’s “Serious 7” Protocols.

Internal communication campaigns aim to provide all employees with information that can help them understand the Group’s strategy, environment and activities, build their sense of belonging and highlight the Group’s values to help strengthen its identity. In 2018, Imerys launched a new Group news and collaborative social platform that supports daily communication and collaborative needs and simplifies how Imerys’ employee connect and work together. This new platform hosts essential information, documentation and protocols, but also social feeds and workspaces, tools and business applications. The new intranet is optimized to enable employees to use tools and resources in a more agile way – including smartphone access to Group level applications. The new intranet facilitates the sharing of projects, initiatives and successes throughout the Group. It is likewise a platform to share information and support discussion on specific topics within specialized communities.

Attached Files: There are no files

PERFORMANCE INDICATORS

• GRI 401-1 Disclosure: New employee hires and employee turnover

Imerys Greece S.A. employees (Milos and Athens facilities) hiring and turnover is depicted in the following table. Employee turnover refer to employees who leave the organization voluntarily or due to dismissal, retirement, or death in service.

Imerys Greece S.A. total educational expenditure for 2018 amounted to 46,612€ for job expertise trainings, management trainings and environmental, health and safety trainings, with 9,438 total training hours.

Attached Files: There are no files

17. Human Rights in the supply chain

ADMINISTRATIVE PRACTICES

Imerys is committed to respecting internationally-recognized human rights, as set out in the International Bill of Human Rights and the ILO’s Fundamental Conventions. The Group is committed to respect human rights and avoid complicity in human rights abuses, as stated in the UN Guiding Principles on Business and Human Rights, and provide access to remedy.

Since 2017, the risk mapping process began with the identification of key ESG risk categories divided between internal and external supplier categories. The initial Group risk assessments for two first pilot geographic areas were conducted at the end of 2017. These first assessments confirmed the validity of the risk framework in addition to generating the assessments results. The second phase of geographic assessments were conducted in 2018 through questionnaires and interviews with business leaders from each of the remaining geographic areas where the Group operates.

The Group management framework is articulated through a series of policies, protocols and procedures based upon the ambitions and commitments expressed in the Code and the CSR Charter. This framework, covering human rights, health, safety and environment, amongst other themes, defines clear requirements for all Group operations. Implementation of Group policies, protocols and procedures are the responsibility of all business and support functions. Based on the Code, Group requirements for all suppliers are clearly defined within the Imerys Supplier Environmental Social and Governance Standards. Across the Group, divisions’ purchasing policies define the process through which the elements of these Standards are implemented in their respective businesses.

Awareness of and training on the requirements of the Group Code are provided to help managers and employees to understand and respect the Code. To support the roll-out of the new Code a specific e-learning module was developed. This e-learning module is compulsory for all Group employee, has been translated in 23 languages and will be delivered throughout 2019 via IM-Pulse, as well as through other delivery channels including in-class training and presentations led by internal experts.

In addition to the aforementioned dedicated e-learning, Imerys also conducted a series of training and awareness raising sessions for purchasing and supply chain professionals on UN Guiding Principles on Business and Human Rights and their application within Imerys. A total of 10 sessions were held in 2018. Within the context of the Group purchasing transformation they offered an opportunity to create greater awareness amongst purchasing professionals around the world of the specific risks and obligations in the management of the Group’s global supply chain.

The assessment of ESG performance of suppliers starts during supplier qualification and onboarding. Screening criteria for the qualification of suppliers includes ESG elements. The Group focuses in particular on assessments and audits of suppliers ranked as “high risk” based on the Group risk mapping and evaluation process described above. In such cases the Group conducts additional due diligence or specialized external third-party reviews prior to contract award. In 2019, the Group will focus on streamlining best practices on supplier onboarding across the Group.

For additional information regarding Imerys Greece S.A. facilities, please refer also to criterion 4: Management of value chain.

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PERFORMANCE INDICATORS

• GRI 412-3 Disclosure: Significant investment agreements and contracts that include human rights clauses or that underwent human rights screening
• GRI 414-1 Disclosure: New suppliers that were screened using social criteria

Based on the ESG risk mapping process and final ranking, suppliers in all the highest risk countries were assessed further. With support of approximately 60 members from purchasing, supply chain and site management, over 600 existing suppliers in 17 countries were screened. At the end of December 2018, nearly 500 of these existing suppliers have been assessed against “red flag” criteria linked to the human rights, health & safety and environment risk scenarios and categorized with a specific risk ranking of low, medium or high by local and Corporate CSR and purchasing teams. The final supplier risk ranking of low, medium or high determines the control measures to be put in place to eliminate or mitigate the potential risk within the supply chain.

In 2019, the Group purchasing policy shall be reviewed to integrate additional considerations related to the updated Standards as well as the risk assessment process undertaken in 2018. As of 2019, all suppliers will be required to sign the Standards, committing to compliance with the requirements stipulated within. In addition to the supplier self-declaration, specific ESG clauses linked to the Code are integrated within supplier contracts as appropriate. Furthermore, the Group General Terms and Conditions for CAPEX projects purchases encompass compliance with the Imerys Code and the Standards.

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18. Corporate Citizenship

ADMINISTRATIVE PRACTICES

Imerys is committed to build positive relationship with communities around its sites and contribute to local social and economic development. During 2018 the following CSR projects were highlighted:

• SD Challenge 2018

For the past 14 years the Group has organized a company-wide competition called the Sustainable Development Challenge (SD Challenge), which serves as an impetus to develop and share best practices, innovations, and technological solutions, each contributing to the Group CSR commitments and supporting progress towards several UN Sustainable Development Goals. In total, over 900 projects have been submitted in the SD Challenge since it was first launched. The Imerys SD Challenge 2018 edition reached a record level of participation with 143 projects submissions representing all the Group geographic areas and divisions. To be considered for the 2018 Challenge, a project must have concretely contributed to one of 8 specific CSR themes and focused on achieving long-term sustainable results together with local partners. Imerys is committed to ensure that the Group SD Challenge continues to inspire greater awareness and understanding of material CSR risks and continues to serve as a platform to support the realization of the Group CSR vision and ambition.

Two initiatives of Imerys Greece S.A. awarded top honors within the 2018 SD Challenge, the "Propagation of rare, endemic and endangered plant species" and “Milos Mining Museum 20th anniversary: an educational and cultural center on Milos island". The first initiative aims to protect and enhance biodiversity by ensuring the long-term survival of six endemic species found on the island. Seeds from the endangered plants are collected and then taken to the Imerys nursery. After careful cultivation, the seedlings are taken to specially selected spots in depleted areas for planting. The second initiative celebrated the 20-years of function of Milos Mining Museum, organizing special activities and events in cooperation with Peripatos Cultural Company. This celebration was also based on the occasion of the International Museum Day 2018 titled “Hyperconnected Museums, new approaches, new publics” and the European Year of Cultural Heritage 2019 “Our Heritage, where the past meets the future”.

• Milos vineyard

Imerys Greece S.A. transformed a rehabilitated perlite mine in Milos Island to a new financial activity via viticulture. Starting from February 2014, approximately 22,300 vines have been planted in a total area of 63.1 acres. In August 2015 the first quality control vine harvest took place, while in August 2016, the first vine harvest was conducted at Milos’ Vineyard. 300 kilos of grapes were turned into wine and the first bottling of wine production took place in 2017. Bottles of wine were distributed to all Imerys Greece S.A. employees. In 2017 1434kg of Assyrtiko grapes were harvested and 800 bottles of wine were produced, while in 2018 1680kg of Assyrtiko grapes were harvested and 1000 bottles of wine were produced.

Through Vineyard initiative, environment is protected and preserved as organic cultivation method is applied. Moreover, irrigation water is recycled, which is an aspect of invaluable importance as water in the Cyclades Islands is in shortage. Four free training seminars with approximately 300 participants have already been provided to the local community, encouraging Milos’ residents to revive small family vineyards using organic agricultural methods. Education on the use of industrial minerals is also encouraged, as prominent examples of Milos’ minerals are used in viticulture and wine production. These minerals are sulfur, protecting the crop from disease in organic winegrowing, bentonite that is used for wine stabilization and perlite that is used in wine clarification. Finally, the activity will also contribute to “alternative” tourism on the island, attracting visitors interested in wine-making and wine-tasting.

• Milos bentonite drying

Every year around 1,000,000 MT of bentonite are mined on Milos Island and almost all of that quantity has to be dried to about 15% on average. Significant energy saving is achieved by exploiting Milos’ climatic conditions - that is high temperature and wind during summer - for the natural pre-drying of bentonite in open fields. This results in approximately 35% annual energy savings, compared to the energy that would be required if industrial drying was exclusively used. It is estimated that some 100,000 MT of water are evaporated on a yearly basis through this field drying process. This is equivalent to actual savings of about 7,500 MT of annual crude oil consumption, corresponding to CO₂ emissions reduction in the range of 24,000 MT per annum.

• Milos nursery and botanical pathway

Milos Plant Nursery and Botanical Pathway are both an environment rehabilitation and an educational destination. The nursery is consisted of 864 types of Milos plant species and a botanical pathway is created by cultivating these plants. The creation of Milos plant nursery dates back in 1994.

• Miloterranean

Miloterranean Geo Experience makes Milos a brand name in tourism. It consists of 8 mapped roots revealing the unique Geology of Milos, each of one consisting a specific guide. The project was launched in 2012 and the 8th path was added in 2017.

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PERFORMANCE INDICATORS

• GRI 201-1 Disclosure: Direct economic value generated and distributed

Imerys Greece S.A. direct economic value distributed consists of facilities’ sponsorships and contribution to local society, as depicted in the attached chart. In 2018, Corporate Social Responsibility (CSR) sponsorships totaled 530,612.12€. This overall amount includes the mandatory municipal financial contribution to Milos, which amounts to 175,919.89€.

Contribution to Milos local society was carried out by:

• Direct contribution to local associations, infrastructure works and conservation of natural environment, such as bentonite drying, nursery and botanical pathway;
• Indirect contribution through various on-going initiatives that promote the cultural as well as the industrial heritage of each area, like activities of Milos Mining Museum (MMM) and Milos Conference Center (MCC);
• “Added” value initiatives such as post-mining use (vineyards) and sustainable tourism (Miloterranean).

Contribution to Athens local society was directed towards:

• Gymnastic Club of Kifissia municipality, where company’s office premises are located;
• Social grocery store of Kifissia municipality;
• Initiatives of Action Aid, WWF and “The Smile of the Child” NGOs.

• GRI 413-1 Disclosure: Operations with local community engagement, impact assessments, and development programs

Total visitors at Milos Mining Museum (MMM) were 10,055. 76.06% were foreigners, basically French and Italians and the rest 23.94% were Greeks. Museum ran 12 educational programs, in which 627 local school students participated. The composition of visitors for 2018 according to their nationality and the number of participants in MMM educational programs is depicted in the attached charts.

For 2018, annual institutions of the "ANASTASIA ANTONIADOU" Award (A.A.A.) and the "ANASTASIA ANTONIADOU" Scholarship (A.A.S.) were offered to local community participants. A.A.A. is addressed to both Imerys’ local employees and Milos residents in order to encourage actions and initiatives in the fields of social, cultural and voluntary contribution. A.A.S. is addressed to women graduates of the Milos or Kimolos islands senior high schools (Lyceums), who successfully stood the entrance examinations for one of the country’s Universities.

In 2018 Milos Conference Center (MCC) – George Eliopoulos was used for 59 days in total and held 6 daily workshops with 680 participants and 42 events with 5,075 participants, such as presentations, awards and cultural events. The total number of participants in MCC events was estimated at 5,755.

Important events that took place in MCC for 2018 are:

• "ANASTASIA ANTONIADOU" Award (A.A.A.) and "ANASTASIA ANTONIADOU" Scholarship (A.A.S.) award ceremony on 14.04 (130 participants);
• The “Ecopolis” 2019 Environmental Awareness awards ceremony by NGO Ecocity, as well as a workshop on geothermal energy, during 02 & 03.06 (200 participants);
• Workshop of Agricultural University of Athens on 18, 19 & 20.06 for college students (40 participants);
• Safety Connect Day of Imerys Milos facilities on 22.06 having the theme “My personal commitment to safety” (400 participants);
• Meetings of faculty of Geology and Geoenvironment college students (University of Athens) on 10.10 (30 participants);
• Christmas event organized by Imerys Milos facilities for employees’ children and children of Milos residents on 08.12 (230 attendants).

In 2018 Milos employees volunteered towards the local community via the following initiatives:

• Participated in blood donation, which took place twice within the year (on April and October), with a total number of 100 collected blood units;
• Fire extinguishing team

Composed of 15 employees, who are trained for emergency situations and fire extinguishing. In 2018, Imerys employees and external partners participated in a fire extinguish in Achivadolimni position.

• Anti-pollution programs

Group of 15 employees, who are trained on dealing with marine oil pollution incidents. This group acts in cooperation with public state bodies.

In 2018 Athens employees supported:

• Special Lyceum of Ilion

Provide students of this special school with school stationery.

• 2nd High School of Intercultural Education at Hellenico

Provided PCs for students of this intercultural students.

• Kifissia gymnastics club

Supported club for buying its annual tracksuits and cardigans for the athletes.

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19. Initiatives and Political Influence

ADMINISTRATIVE PRACTICES

Imerys Greece S.A. has active participation to the following organizations:

Environmental and Sustainability Organizations

• SEV Business Council for Sustainable Development

Imerys Greece S.A. is a founding member of this organization. Mr. Athanasios Kefalas, General Manager Bentonite and Perlite Intermediates, is a board member.

• SEV Health & Safety Working Group

EHSQ and Supporting Services Manager, Mr. Yannis Karavelakis, is a member of the relevant working group.

Industry Organizations

• Industrial Minerals Associations for Europe (IMA-Europe)
• European Bentonite Association (EUBA) branch
• European Association of Mining Companies (Euromines)
• Greek Mining Enterprises Association (SME)

Imerys Greece S.A. is an enterprise – member of SME. Mr. Athanasios Kefalas, General Manager Bentonite and Perlite Intermediates is the president of Board of Directors, starting from 2017.

• SEV – Hellenic Federation of Enterprises
• Association of Industries & Exporting Enterprises of Milos

CSR Organizations

• CSR Europe
• CSR Hellas

Imerys Greece S.A. does not receive any financial assistance from government agencies and is not subsidized by the Greek state budget.

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PERFORMANCE INDICATORS

• GRI 415-1 Disclosure: Political contributions

Imerys Greece S.A. has not donated to any political party during the reference year and did not contributed to them, either financially, or in any other way.

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20. Corruption prevention and alleviation

ADMINISTRATIVE PRACTICES

The Group’s charters, policies and manuals are grouped together in the Blue Book, which all employees can consult on the Group Intranet OneImerys. This fundamental set of rules forms the framework for the Group’s operations. It applies to all Imerys’ activities and the companies it controls. These ethical values cover a spectrum of topics such as:

• environmental and human rights protection;
• local community relations;
• workplace diversity;
• safety and health;
• confidentiality;
• the prevention of fraud and corruption;
• insider trading and conflict of interest;
• fair competition;
• transparency and integrity.

Essential part of the Blue Book is the Anti-fraud and anti-bribery policy. Imerys has a zero tolerance policy on both fraud and bribery. Imerys’ Anti-fraud and anti-bribery policy confirms and summarizes the responsibilities applicable to all of the Imerys directors, officers and employees, persons purporting to act in that capacity or other persons or entities which perform services for or on behalf of Imerys. It also sets out the steps to be taken to prevent, detect and report fraud and bribery and describes the disciplinary actions to which those who engage in such conduct will be subject. This policy and its relevant procedures extend to conduct by third parties (e.g., joint venture partners, vendors, contractors, consultants and agents) whenever such conduct involves the misuse of Imerys funds or other Imerys property or could be attributed to Imerys. The program aims to comply with all relevant applicable laws; its baseline follows the OECD recommendations however its scope is wider: in addition to foreign bribery, it encompasses private bribery and fraud in general.

In 2016, Imerys became a signatory member of the United Nations Global Compact (UNGC) and has thus committed to base its business approach on the 10th Anti-Corruption Principle, between others, stating that “Businesses should work against corruption in all its forms, including extortion and bribery”.

Internal Audit is responsible for evaluating the internal controls that have been implemented and recommending any steps that may be needed to improve controls and thus mitigate risks. The risk assessments that are conducted by Internal Audit should provide the basis upon which audit plans are devised and against which internal controls are tested. Internal audits can serve simultaneously as a deterrence and detection mechanism. If Internal Audit becomes aware of possible fraud or bribery, a duly authorized representative of Internal Audit should notify the Group General Counsel immediately of the suspicions that have arisen.

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PERFORMANCE INDICATORS

• GRI 205-3 Disclosure: Confirmed incidents of corruption and actions taken

Within Imerys Group Blue Book, which is an online policies and procedures intranet, 2 fraud alerts were published during 2018. These alerts had to do with:

• Conflicts of interest in a purchasing scheme

Two employees of an Imerys entity developed a network of services providers in the toll manufacturing and transportation sectors, having interests in several companies:

- The Head of Accounting had indirect interests in those companies through close family relatives who were significant shareholders. In addition, this employee was also the accountant of one of them.

- The Sales manager had direct interests in the transportation company, being a 25% shareholder. Ordering of transportation was managed by the Sales department.

• Private corruption in a Sales scheme

The General Manager of an Imerys entity set up a corruption scheme whereby some employees gave bribes in cash to some customers in order to obtain contracts for the supply of goods and installation services as well as to eliminate any potential complaints that may arise from the non-conformity of goods.

In every fraud alert, details are given for how the fraud is facilitated and the corrective action proposed in order not similar incidents to take place. There is also a constant reminder that reporting and communication are keys towards avoiding fraud acts.

During 2018, no fraud or corruption issues have been detected in Imerys Greece S.A..

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