Home / BIC Graphic Difference / Our Compliance

BIC Graphic is a leader in product safety, quality assurance, social responsibility, supply chain security and environmental stewardship. This includes C-TPAT certification, FDA regulations, technology standards and Prop 65 compliance.

Quality Certification Alliance

Quality Certification Alliance (QCA)

The promotional product industry's only independent, not-for-profit organization dedicated to helping companies provide safe products, has granted QCA Accreditation to BIC Graphic North America.

Product Safety Aware

PPAI Product Safety Awareness Program

This program is part of a larger PPAI initiative to create confidence in promotional products as an advertising medium at every level.

C-TPAT Tier II Certified

C-TPAT Tier II Certified

BIC Graphic is C-TPAT Tier II certified by U.S. Customs which evidences our superior commitment to supply chain security.

Product Safety

BIC Graphic products are rigorously tested to confirm compliance with CPSIA and other North American product safety laws and standards.

Leading Technology Standards

Our technology items are tested to applicable UL, UN and FCC standards and requirements.


All of our plastic drinkware products are BPA FREE.

FDA Regulations

Our Health, Wellness & Safety products go through extensive analysis to confirm compliance with all applicable FDA regulations.

Prop 65

The majority of BIC Graphic's product SKUs are Prop 65 compliant and do not require a Prop 65 label when shipping to California.

Icons shown are for illustrative purposes only and are not intended to imply that any governmental body or organization has endorsed BIC Graphic's compliance program.

Compliance List

  1. The Consumer Product Safety Improvement Act (CPSIA) requires the certificates listed in the chart below. Please click on the product number to retrieve a certificate. Certificates of Compliance apply to CHILDREN'S PRODUCTS (products that are designed or intended primarily for use by children 12 and under). General Conformity Certificates ("GCCs") apply to NON-CHILDREN'S PRODUCTS. The Consumer Product Safety Commission has recently defined what types of NON-CHILDREN'S PRODUCTS (general use) require a GCC.

    Children's Products

    ItemNameLast Updated
    All Coloring Books August 13, 2018
    All All About Me Books August 10, 2018
    AP3200 A Step Ahead Messenger February 8, 2019
    AP5080 Cutie Patootie Slingpack February 08, 2019
    10162 Beach Ball October 23, 2018
    15039 Drawstring Backpack February 11, 2019
    15660 Non-Woven Drawstring Backpack February 21, 2019
    15734 Clear Game Drawstring Backpack February 11, 2019
    15735 Clear Game Tote January 31, 2019
    15762 Clear Zippered Tote February 04, 2019
    15763 Clear Backpack January 30, 2019
    15797 Clear Cinch Backpack March 14, 2019
    26078 Light Up YoYo February 19, 2019
    30434 The Bank'r with Locking Key August 24, 2018
    32121 Office Mini Spinner August 14, 2018
    32186 3-Port USB 2.0 Spinner Hub February 11, 2019
    32274 3D Arm Ring Spinner October 22, 2018
    32284 Piggy Bank with Locking Key December 3, 2018
    40242 Kid's Fun Pocket Pack September 3, 2018
    40250 Baby Bib October 23, 2018
    40288 Splatter Brain in a Dish October 23, 2018
    40697 Crayons August 13, 2018
    46172 Spinner with Bottle Opener August 10, 2018
    55872 Black 7-Piece Colored Pencil Set January 17, 2019
    55873 Black 7-Piece Tall Colored Pencil Set January 17, 2019
    55874 7-Piece Erasable Colored Set January 18, 2019
    61675 Mini Hockey Stick August 14, 2018
  2. New Products - All proposed New Products must pass comprehensive testing prior to being released for mass production and sale.

    Benchmarked Products - When the production of an existing product is moved to a new manufacturer that product must pass comprehensive testing prior to being released for mass production and sale.

    Modified Products - When an existing product is modified, the modified components must pass comprehensive testing prior to being released for mass production and sale.

    Child Products - All Child Products must be re-tested annually. A Child Product is a product that is designed or intended primarily for use by children 12 and under. A Toy is a Child Product that is designed or intended primarily for use by children 12 and under during play. A Childcare Article is a Child Product that is designed or intended for use by children 3 years and under to facilitate sleep, feeding, teething and sucking.

    CPCs and GCCs - Child Product Certificates (CPCs) are posted on www.bicgraphic.com and updated each time a Child Product is tested. A Child Product Certificate states when and where the product was tested and the results of those tests.

    Imprint Inks - All imprint inks and other decorating materials are tested each year to industry standards.

    Re-Testing Frequency - The frequency of retesting is established for each product based upon the potential risks associated with the product, the prior testing history of the product, the standards that apply to it and the sales volume of the product.

    Corrective Actions - Any product that fails a standard is reformulated and retested to confirm compliance. The only exception is when a product fails a Prop 65 standard and cannot be reformulated (ex. lead crystal). In that instance, a Prop 65 warning will be added to it when shipping to California.

    Comprehensive Testing - We test all colors of all components of all products to all applicable standards.

    Supplier Score Cards - BIC Graphic monitors its Suppliers with Supplier Score Cards to ensure continuing quality and compliance.

    Label Review - All products are reviewed for proper labels, warnings and safe use instructions.

    Polybag Warnings - Our polybag warnings meet or exceed the most stringent legal requirements.

    Risk Assessments - A Risk Assessment is conducted on each proposed New Product, Benchmarked Product and Modified Product to determine whether or not the product has a defect or hazard due to its design, materials or construction. Hazardous products will be rejected, modified to eliminate the hazard or permitted with appropriate warnings and safe use instructions.

    Test Reports – Test reports can be found on the product page of the BIC Graphic website.

  3. California Proposition 65 (“Prop 65”) is a warning label law that applies to all products offered for sale in CA (including products shipped to another state and later re-shipped to CA). If a product contains a chemical in excess of the Prop 65 limit, the product can still be sold in California provided a Prop 65 warning is attached to the product when it enters California. BIC Graphic tests all of its products to Prop 65 standards. If any component fails a Prop 65 standard, BIC Graphic will pursue a reformulation and re-testing of that component to ensure that it complies with Prop 65 chemical limits. If for any reason the product cannot be reformulated to comply with all Prop 65 standards, the product will be placed on a list designating it as a product that must have a Prop 65 warning applied to it when the product is to be shipped to California.

  4. BIC Graphic (“BG”) is committed to operating its business in a safe, sustainable and environmentally friendly manner. The protection of our consumers, workers and the environment are paramount.  Our sustainable development plan incorporates, among other things, the following principals: (1) Product Safety and Regulatory Compliance, (2) Quality Assurance, (3) Social Responsibility, (4) Supply Chain Security, and (5) Environmental Stewardship. This Restricted Substances List (“RSL”) is a key element to BG’s continuing efforts to further these ideals. BG acknowledges that our Suppliers are vital partners in this endeavor.  As a consequence, these policies and procedures apply to all companies that manufacture and/or sell finished products (the “Products”) to BG (collectively, “Suppliers”).

    The objectives of this RSL are to:

    1. Ensure that chemicals used in the manufacture of the Products comply with the chemical content and chemical exposure laws of every governmental jurisdiction in which the Products are manufactured and sold; and
    2. Ensure that the Products do not expose consumers and others handling them to levels of chemicals which would adversely affect their health or safety.

    Suppliers must ensure that the chemicals used in the manufacture of the Products are used in a manner consistent with the requirements of the chemical supplier and other applicable chemical use requirements.

    This RSL is an important part of BG’s product stewardship and environmental sustainability programs, and Suppliers must share this RSL with all companies that supply materials, parts and chemicals that are used to produce the Products.  Suppliers are responsible for ensuring that all of the companies that they purchase materials, parts and chemicals from for use in manufacturing the Products are in compliance with the bans, restrictions and requirements described or referred to in this RSL.

    We require our Suppliers to study this document carefully, implement management processes in their operations to comply with these requirements and communicate the information to their internal teams.  This RSL supersedes all prior versions of the BG RSL. As a Supplier of Products to BG, you are required to understand the RSL product standards and deliver only compliant products to BG.  You are also responsible for seeking guidance from BG in any situation where you may have doubts or uncertainties about your Product’s compliance with BG’s RSL Product standards. 

    Each Supplier, by manufacturing or selling a Product to BG, represents and warrants that each of the Products complies in all material respects with this RSL and all applicable laws.  Each Supplier does hereby agree to indemnify, defend and hold BG harmless from any claim, loss, damage, expense and other harm that results from such Supplier’s non-compliance with this RSL or any applicable laws.

    Restricted Substance (CAS #)Limit
    Alkylphelols (AP) & Alkylphenol Ethoxylates (APEO)
    Nonylphenols (NP) (CAS# multiple isomers)
    Octylphenols (OP) (CAS# multiple isomers)

    Nonylphenol ethoxylate (C2H4O)nC15H24O (CAS# multiple isomers)
    Octylphenol ethoxylate (C2H4O)nC14H22O (CAS# multiple isomers)
    Sum of NP & OP: 100 ppm (preparations)
    Sum of NPEO & OPEO: 100 ppm (preparations)
    Cleaning agents, processing of leather products, biocides, pesticides, cements, glues and metal processing.
    Actinolite (77536-66-4)c Amosite (12172-73-5)
    Anthrophylite (77536-67-5)
    Chrysotile (12001-29-5)
    Crocidolite (12001-28-4)
    Tremolite (77536-68-6)
    None Detected
    (each type)

    Asbestos has been used in shingles, siding, drywall, vinyl floor tile, pipe insulation and other building materials due to its heat and fire insulating properties as well as its acoustic properties. When friable it is widely known to cause respiratory diseases such as lung cancer, mesothelioma and asbestosis.
    Azo Colorants
    (Restricted aromatic amines – from Azo dyes)

    4-Aminodiphenyl (92-67-1)
    Benzidine (92-87-5)
    4-Chloro-o- Toluidine (95-69-2)
    2- Napthylamine (91-59-8)
    o-Aminoazotoluene (97-56-3)
    2-Amino-4-nitrotoluene (99-55-8)
    2,4 Diaminoanisole (615-05-4)
    3,3-Dimethylbenzidine (119-93-7)
    4,4 Diaminodiphenylmethane (101-77-9)
    3,3-Dichlorobenzidine (91-94-1)
    3,3- Dimethoxybenzidine (o-Dianisidine) (119-90-4)
    3,3- Dimethyl-4,4’-diaminodiphenylmethane (838-88-0)
    p-Chloroaniline (106-47-8)
    p-Cresidine (120-71-8)
    4,4-Methylene-bis-(2-chloraniline) (101-14-4)
    4,4- Oxydianiline (101-80-4)
    4,4- Thiodianiline (139-65-1)
    2,4- Toluenediamine (95-80-7)
    o-Toluidine (95-53-4)
    2,4,5-Trimethylaniline (137-17-7)
    o-Anisidine (90-04-0)
    4-Amino-azobenzene (60-09-3)
    2,4-Xylidine (95-68-1)
    2,6-Xylidine (87-62-7)
    30 ppm
    (each amine)

    Most colored textile and leather articles are treated with Azo Dyes and pigments. Aromatic Amines derived from azo colorants (dyes) are found in textile fibers, including natural, man-made, regenerated, and blended fibers. The EU standard EN 14362-1:2012 is used to detect EU banned aromatic amines derived from azo colorants (dyes) in textile fibers. This EU standard is also relevant for all colored textiles, e.g. dyed, printed, and coated textiles. Azo dyes have vivid colors, especially reds, oranges, and yellows. Azo dyes are carcinogenic.
      Dimethyl Fumarate (DMF) (624-49-7) 1 ppm
    DMF is a biocide that is used to protect against mold growth in shoes and other apparel. Some individuals are allergic upon skin contact. A major side effect to exposure to DMF is progressive multifocal leukoencephalopathy (damage to the white matter of the brain – usually fatal).
    Dioxins & Furans
    Group 1:
    2,3,7,8-Tetrachlorodibenzo-p-dioxin (1746-01-6)
    1,2,3,7,8-Pentachlorodibenzo-p-dioxin (40321-76-4)
    2,3,7,8-Tetrachlorodibenzofuran (51207-31-9)
    2,3,4,7,8-Pentachlorodibenzofuran (57117-31-4)

    Group 2:
    1,2,3,4,7,8-Hexachlorodibenzo-p-dioxin (39227-28-6)
    1,2,3,7,8,9-Hexachlorodibenzo-p-dioxin (19408-74-3)
    1,2,3,6,7,8-Hexachlorodibenzo-p-dioxin (57653-85-7)
    1,2,3,7,8-Pentachlorodibenzofuran (57117-41-6)
    1,2,3,4,7,8-Hexachlorodibenzofuran (70648-26-9)
    1,2,3,7,8,9-Hexachlorodibenzofuran (72918-21-9)
    1,2,3,6,7,8-Hexachlorodibenzofuran (57117-44-9)
    2,3,4,6,7,8-Hexachlorodibenzofuran (60851-34-5)

    Group 3:
    1,2,3,4,6,7,8-Heptachlorodibenzo-p-dioxin (35822-46-9)
    1,2,3,4,6,7,8,9-Octachlorodibenzo-p-dioxin (3268-87-9)
    1,2,3,4,6,7,8-Heptachlorodibenzofuran (67562-39-4)
    1,2,3,4,7,8,9-Heptachlorodibenzofuran (55673-89-7)
    1,2,3,4,6,7,8,9-Octachlorodibenzofuran (39001-02-0)

    Group 4:
    2,3,7,8-Tetrabromodibenzo-p-dioxin (No CAS #)
    1,2,3,7,8-Pentabromodibenzo-p-dioxin (No CAS #)
    2,3,7,8-Tetrabromodibenzofuran (No CAS #)
    2,3,4,7,8-Pentabromidbenzofuran (No CAS #)

    Group 5:
    1,2,3,4,7,8-Hexabromodibenzo-p-dioxin (No CAS #)
    1,2,3,7,8,9-Hexabromodibenzo-p-dioxin (No CAS #)
    1,2,3,6,7,8-Hexabromodibenzo-p-dioxin (No CAS #)
    1,2,3,7,8-Pentabromodibenzofuran (No CAS #)
    None Detected
    (all Dioxins & Furans)

    Dioxins are by-products of manufacturing processes such as waste incineration, metal production and fossil-fuel and wood combustion. They are carcinogenic.

    Furans are chemicals used as a starting point to creating specialty chemicals. They are carcinogenic.
    Disperse Dyes – Sensitizing
    Disperse Blue 1 (2475-45-8)
    Disperse Blue 3 (2475-46-9)
    Disperse Blue 7 (3179-90-6)
    Disperse Blue 26 (3860-63-7)
    Disperse Blue 35 (12222-75-2)
    Disperse Blue 102 (12222-97-8)
    Disperse Blue 106 (12223-01-7)
    Disperse Blue 124 (61951-51-7)
    Disperse Red 1 (2872-52-8)
    Disperse Orange 3 (730-40-5)
    Disperse Orange 37/59/76 (13301-61-6)
    Disperse Yellow 3 (2832-40-8)
    Disperse Yellow 23 (6250-22-3)
    None Detected
    (each dye)

    Disperse Dyes are the only water-insoluble dyes that are used to dye polyester and other synthetic fabrics.
    Flame Retardants
    Pentabromodiphenyl ether (PentaBDE) 3-isomers (32534-81-9)
    Octabromodiphenyl ether (OctaBDE) 4-isomers (32536-52-0)
    Tetrabromobisphenol A
    Chlorinated Parrafins
    Antimony Trioxide
    Polybrominated diphenyl ether (PBDE)
    Tetrabromophthalate (TBPH)
    tris(1-chloro-2-propyl)phosphate (TCPP)
    Tetrabromobenzoate (TBB)
    Tri-o-cresyl phosphate (78-30-8)
    Tris(2-chloroethyl) phosphate (115-96-8)
    tris-(2,3,-dibromopropyl)phosphate (TRIS) (126-72-7)
    polybromobiphenyls (PBB) (59536-65-1)
    tris-(aziridinyl)-phosphineoxide (Tris(1-aziridinyl)phosphine oxide) (TEPA) (545-55-1)
    Pentabromodiphenyl ether (PentaBDE) (32534-81-9)
    Octabromodiphenyl ether (OctaBDE) (32536-52-0)
    bis (2,3-dibromopropyl)phosphate (5412-25-9)
    decabromodiphenyl ether (DecaBDE) (1163-19-5)
    None Detected
    (each flame retardant)

    Flame Retardants are toxic chemicals that are added to manufactured materials, such as plastics and textiles, and surface finishes and coatings. Flame retardants inhibit or delay the spread of fire by suppressing the chemical reactions in the flame or by the formation of a protective layer on the surface of a material. Flame retardants are typically added to industrial and consumer products to meet flammability standards for furniture, textiles, electronics, and building products like insulation.
    Brominated Flame Retardants have been found in the environment and in organisms including humans.
    Flourinated Greenhouse Gases None Detected
    Flourinated Greenhouse Gases are released into the atmospheric from burning carbon fuels and use of products that include them (formerly chlorofluorocarbons from aerosol sprays). These gases include hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF6)—which are potent GHGs that are believed to contribute to global warming. Countries are transitioning away from chlorofluorocarbons (CFCs), hydrochlorofluorocarbons (HCFCs), halons, and other ozone-depleting substances.
    Antimony (Sb)
    Arsenic (As) (7440-38-2)
    Barium (Ba)
    Cadmium (Cd) (7440-43-9)

    Lead (Pb) (7439-92-1)

    Mercury (Hg) (7439-97-6)

    Chromium (Cr VI) (7440-47-3)
    Selenium (Se) (7782-49-2)
    Nickel (Ni) – Release (7440-02-0)

    Tin (Sn) Organotins
    MBT (7440-31-5)
    Tributyltin (TBT) (56573-85-4)
    Dibutyltin (DBT) (1002-53-5)
    Triphenyltin (TPhT) (668-34-8)
    60 ppm
    25 ppm (soluble As)
    1,000 ppm
    75 ppm – Child (soluble Cd)
    300 ppm – Adult (total Cd)
    90 ppm paint
    100 ppm substrate
    10 ppm paint (Canada Toy)
    60 ppm paint & substrate (US Toy)
    60 ppm paint & substrate
    500 ppm paint & substrate
    0.5 µg/cm²/week (Metal in direct and prolonged contact with the skin; 0.03 µg / cm² / week for piercings)

    1 ppm (each Organotin)

    Antimony is used in flame proofing materials, paints and enamels. It is used in semi-conductors for diodes.
    Arsenic is used to make pesticides, herbicides and insecticides. It forms an alloy with lead for batteries. Found in cotton and cotton synthetic blend fabrics, pigments, wood preservatives and optical glass.
    Barium is used as a glass stabilizer and pesticide. It can be found in glassware, rubber, magnets and glazed ceramic pottery.
    Cadmium is used as a pigment in dyes and paints, as an alloy to metals in jewelry, solder and batteries. It is also used to electroplate and protect metals from corrosion.
    Lead is used in building construction, lead-acid batteriesbullets and shot, fishing gear, weights (wheels, fishing, exercise, scuba diving, ballast on sailboats), as part of solders, pewtersfusible alloys and as a radiation shield. Lead is a neurotoxin. Lead is alloyed with copper and its alloys (namely, brass and bronze).
    Brass is a metal alloy made of copper and zinc.
    Bronze is principally an alloy of copper and tin. Lead compounds are used as a coloring element in ceramic glazes, notably in the colors red and yellow. Lead is frequently used in polyvinyl chloride (PVC) plastic.
    Mercury is used in glass thermometers, gauges, batteries scientific instruments, street lights, lighted signs.
    Cr VI (hexavalent chromium) is a toxic and carcinogenic chemical element. Cr and Cr III are not toxic or carcinogenic. It is used in the processing of leather products, as a wood preservative for treated lumber and for metal plating.
    Selenium is used to decolorize glass and acts as a catalyst in many chemical reactions. It can be found in glass, shampoo and paint.
    Nickel is used to make stainless steel, alnico magnets, coins, rechargeable batteries, electric guitar strings, microphone capsules and plating on plumbing fixtures.
    Organotins Organotin compounds are chemical compounds with tin–carbon bonds. Of the compounds of tin, the organic derivatives are the most useful commercially. Some organotin compounds are highly toxic and have been used as biocides. The major commercial application of organotin compounds is in the stabilization of PVC plastics. In the absence of such stabilizers, PVC would otherwise rapidly degrade under heat, light, and atmospheric oxygen, resulting in discolored, brittle products. Some organotin compounds are relatively toxic, with both advantages and problems. They are used for biocidal properties as fungicides, pesticides, algaecides, wood preservatives, and antifouling agentsTributyltin oxide is used as a wood preservative. Tin forms several inter-metallic phases with lithium metal, making it a potentially attractive material for battery applications.
    N-Nitrosimine None Detected
    Nitrosamines are carcinogens that are used in the manufacture of some cosmetics, pesticides, and in most latex and rubber products.
    Pentachlorophelol (PCP), its salts and esters (87-86-5 PCP) None Detected
    PCP is a highly toxic compound that is used as an herbicide, insecticide, fungicide, algaecide and disinfectant and as an ingredient in anti-fouling paint. Used to treat leather, wood and rope.
    Tetrachlorophenol (TeCP) (25167-83-3) None Detected
    Perfluorooctane sulphonate (PFOS) and
    PFOS metallic salt, halogenide, amide and
    other derivatives (no CAS #)

    Perfluorooctanoic acid (PFOA)
    1 µg/m2

    PFOS is a global pollutant that was the key ingredient in Scotchgard, a fabric protector made by 3M, and numerous stain repellents. PFOS together with PFOA, have been used to make aqueous film forming foam (“AFFF”), a component in fire-fighting foams. PFOS compounds are also used as water and oil repellants for textiles, paper and leather.
    PFOA has been used as a water and oil repellant in fabrics and leather and in the production of floor waxes. It is found in stain resistant carpets, carpet cleaning liquids, microwave popcorn bags, some cookware and PTEE such as Teflon.
    Aldicarb (116-06-3)
    Aldrin (309-00-2)
    Chlordane (57-74-9)
    Chlordimeform (6164-98-3)
    Dichloro-diphenyl-dichloro ethane (DDD) (72-54-8)
    Dichloro-diphenyl-dichloro ethylene (DDE) (72-55-9)
    Dichloro-diphenyl-trichloro ethane (DDT) (50-29-3)
    Dicofol (115-32-2)
    Dieldrin (60-57-1)
    Endrin (72-20-8)
    Heptachlor (76-44-8)
    Heptachlor epoxide (1024-57-3)
    Hexachlorobenzene (118-74-1)
    Hexachlorocyclohexane (HCH, all isomers) (608-73-1)
    Isodrin (465-73-6)
    Kelevane (4234-79-1)
    Kepone (chlordecone) (143-50-0)
    Lindane (58-89-9)
    Malathion (121-75-5)
    Methoxychlor (72-43-5)
    Methyl Parathion (298-00-0)
    Mirex (2385-85-5)
    Monomethyl-dibromo-diphenyl methane (99688-47-8)
    Monomethyl-dichloro-diphenyl methane (81167-70-8)
    Monomethyl-tetrachloro-diphenyl methane (76253-60-6)
    Parathion (56-38-2)
    Perthane (72-56-0)
    Quintozene (82-68-8)
    Strobane (8001-50-1)
    Telodrin (297-78-9)
    Timiperone(DTTB) (57648-21-2)
    Toxaphene (8001-35-2)
    2-(2,4,5-trichlorophenoxy) propionic acid (2,3,5-TP) (93-97-1) its salts, and 2-(2,4,5-trichlorophenoxy compounds (No CAS #)
    2,4,5-trichlorophenoxyacetic acid (2,4,-T) (93-76-5), its salts, and 2,4,5-trichlorophenoxyacetyl compounds (No CAS #)
    2,4-Dichlorophenoxyacetic acid, its salts and compounds (94-75-7)
    None Detected
    (each Pesticide)
    pH - Textiles 4.0 – 7.0
    All esters of o-phthalic acid including but not restricted to: di-isononyl phthalate (DINP) (28553-12-0) di(ethylhexyl) phthalate (DEHP) (117-81-7) di-n-octyl phthalate (DnOP) (117-84-0) di-iso-decyl phthalate (DIDP) (26761-40-0) butyl benzyl phthalate (BBP) (85-68-7) dibutyl phthalate (DPB) (84-74-2) di-isobutyl phthalate (DIBP) (84-69-5)

    Other Plasticizers
    Triphenyl phosphate (115-86-6) Tri-o-cresyl phosphate (78-30-8) Tri-m-cresyl phosphate (563-04-2) Tri-p-cresyl phosphate (78-32-0)
    1,000 ppm
    (each phthalate)

    Phthalates are plasticizers – they are found in PVC, soft plastic & rubber, imitation leather & neoprene.

    None Detected
    (each plasticizer)
    Polychlorinated Biphenyls (PCBs) (1336-36-3) None Detected
    Because of PCBs' environmental toxicity and classification as a persistent organic pollutant, PCB production was banned in the US in 1979. PCBs are used in coolants and insulating fluids for transformers (transformer oil) and capacitors, such as those used in old fluorescent light ballasts, hydraulic fluids, lubricating and cutting oils, carbonless copy ("NCR") paper, as plasticizers in paints and cements, stabilizing additives in flexible PVC coatings of electrical cables and electronic components, pesticide extenders, flame retardantssealants for caulkingadhesives and wood floor finishes.
    Polychlorinated Terphenyls (PCTs) (No CAS #) None Detected
    PCTs are typically produced and used as mixtures with varying degrees of chlorination. PCTs were once used as heat transfer agents in electric transformers, as plasticizers, as lubricating oils and as flame-retardants. Their production and use has been largely phased out due to environmental and safety concerns.
    Short Chain Chlorinated Paraffins (SCCP)
    with C10-C13 (85535-84-8)
    1,000 ppm
    SCCPs are used as plasticizers, flame retardants, additives in metal working fluids, in sealants, paints, adhesives, textiles, leather fat and coatings. They are toxic and carcinogenic.
    Volatile Organic Compounds (VOCs)
    Pentachloroethane (76-01-7)
    Tetrachloromethane (Carbon tetrachloride) (56-23-5)
    1,1,1,2-Tetrachloroethane (630-20-6)
    1,1,2,2-Tetrachloroethane (79-34-5)
    1,1,1-Trichloroethane (71-55-6)
    1,1,2-Trichloroethane (79-00-5)
    1,1-Dichloroethylene (75-35-4)
    Trichloroethylene (79-01-6)
    Tetrachloroethylene (127-18-4)
    o-Cresol (95-48-7)
    p-Cresol (106-44-5)
    N,N-Dimethylacetamide (127-19-5)
    Dimethylsulfoxide (67-68-5)
    Dimethyl formamide (68-12-2)
    Ethylene glycol monobutyl ether (111-76-2)
    Formaldehyde (50-00-0)
    Methylene Chloride (75-09-2)
    n-hexane (110-54-3)
    n-methyl pyrrolidone (872-50-4)
    4,4’-methylenebis (2-chloraniline) (101-14-4)
    Phenol (108-95-2)
    Tetrachloroethylene (127-18-4)
    1,1,1-trichloroethane (71-55-6)
    Toluene (108-88-3)
    2,4-toluene diisocyanate (584-84-9)
    Toluene-2,6-Diisocanate (91-08-7)
    Trichloroethylene (79-01-6)
    Xylene – all isomers (1330-20-7)
    Trichloromethane (67-66-3)
    1,1,2-Trichloroethane (79-00-5)
    1,1-Dichloroethylene (75-35-4)
    1,000 ppm
    (each VOC)

    VOCs are a group of chemicals that are used in a wide variety of applications. They are damaging to the environment and many are cancer causing.
    Acrylamide (79-06-1)
    Bisphenol-A (BPA) (80-05-7)
    Phenol (108-95-2)
    Styrene (100-42-5)
    A monomer is a molecule that binds to other molecules to form a polymer. This process is called polymerizationEthylene gas is the precursor monomer for polyethylene. BPA is the precursor monomer for polycarbonate. Vinyl chloride leads to PVC.

    None Detected
    None Detected
    10 ppm
    27 µg/day (Prop 65 proposed NSRL)

    Acrylamide has been found in some cooked starchy foods. As of 2014 it is still not clear whether acrylamide consumption increases a people's risk of developing cancer. Acrylamide is a possible carcinogen in other exposures and is related to neurotoxicity.
    BPA is used to make certain plastics and epoxy resins. Plastic with BPA in it is clear and tough. It is used to make plastic baby bottles, sippy cups and adult use water bottles.
    Polycarbonate, ABS and other plastics in contact with food, drink or skin. It is also used to coat the inside of food and beverage cans as well as to make thermal paper (ex. cash register receipts). Plastics that are marked with Resin Identification Codes (“RIC”) 1, 2, 3, 4, 5 & 6 are very unlikely to contain BPA. Some, but not all, plastics marked with RIC 7 may be made with BPA. Type 7 is the catchall class and some Type 7 plastics such as polycarbonate are made with BPA. BPA can be found in limited amounts in ABS plastic and PVC due to contamination of plastic pellets with regrind pellets from polycarbonate plastic production. BPA is a hormone disruptor, especially in babies and young children.
    Phenol is primarily used to synthesize plastics and related materials. The major uses of phenol, consuming two thirds of its production, involve its conversion to precursors for plastics. Condensation with acetone gives bisphenol-A, a key precursor to polycarbonates and epoxide resins. Condensation of phenol, alkylphenols, or diphenols with formaldehyde gives phenolic resins, a famous example of which is Bakelite. Partial hydrogenation of phenol gives cyclohexanone, a precursor to nylon. Phenols are corrosive to the eyes, skin and respiratory tract.
    Styrene leads to polystyrene. The presence of the vinyl group allows styrene to polymerize. Commercially significant products from styrene include polystyrene, ABS plastic and styrene-butadiene (SBR) rubber. Styrene is a toxin to the gastrointestinal tract, kidneys and respiratory system. It is considered by many to be a human carcinogen.
    Pentachlorophenol (PCP) and its salts
    Lindane (58-89-9) Cyfluthrin (68359-37-5)
    Cypermethrin (52315-07-8)
    Deltamethrin (52918-63-5)
    Phenol (108-95-2)
    1,2-Benzylisothiazolin-3-one (2634-33-5)
    2-methyl-4-isothiazolin-3-one (2682-20-4)
    5-chloro-2-methyl-4-isothiazolin-3-one (26172-55-4)
    Formaldehyde (50-00-0)
    None Detected
    None Detected
    None Detected
    None Detected
    None Detected
    None Detected
    None Detected
    None Detected
    None Detected
    75 ppm

    PCPs are used as pesticides, herbicides, insecticides, fungicides, algaecides, and disinfectants and as an ingredient in anti-fouling paint. Other applications include leather, masonry, wood preservation, cooling tower water and, rope. Long term exposure to PCP is associated with cancer and damage to the liver, kidneys, blood and nervous system. Formaldehyde is mainly used in the production of industrial resins such as for particle board, plywood, carpeting and coatings. It is a known carcinogen. Used to make fabrics crease resistant. Used to treat warts. Used to embalm corpses.
    Solvents (Migration)
    Group 1
    Trichloroethylene (79-01-6)
    Dichloromethane (75-09-2)

    Group 2
    2-Methoxyethyl acetate (110-49-6)
    2-Ethoxyethanol (110-80-5)
    2-Ehtoxyethyl acetate (111-15-9)
    Bis (2-methoxyethyl) ether (111-96-6)
    2-methoxypropyl acetate (70657-70-4)

    Group 3
    Methanol (67-56-1)
    Nitrobenzene (98-95-3)
    Cyclohexanone (108-94-1)
    3,5,5-trimethyl-2-cyclohexen-1-one (isophorone 78-59-1)
    Toluene (108-88-3)
    Ethylbenzene (100-41-4)
    o,m,p-xylene (95-47-6, 108-38-3, 106-42-3)
    Benzene (71-43-2)
    None Detected
    0.06 mg/L

    0.5 mg/L (sum total of Group 2)

    5 mg/L
    None Detected
    46 mg/L
    3 mg/L
    2 mg/L
    1 mg/L
    2 mg/L (sum total)
    5 mg/kg
    Solvents (Inhalation)

    Toluene (108-88-3)
    Ethylbenzene (100-41-4)
    o,m,p-xylene (95-47-6, 108-38-3, 106-42-3)
    Mesitylene (1,3,5-trimethylbenzene 108-67-8)
    Trichloroethylene (79-01-6)
    Dichloromethane (75-09-2)
    n-Hexane (110-54-3)
    Nitrobenzene (98-95-3)
    Cyclohexanone (108-94-1)
    Isophorone (78-59-1)
    Benzene (71-43-2)
    260 µg/m3
    5000 µg/m3
    870 µg/m3 (total)
    2500 µg/m3
    None Detected
    3000 µg/m3
    1800 µg/m3
    None Detected
    136 µg/m3
    200 µg/m3
    None Detected
  5. BIC Graphic Policy on Social Accountability

    1. BIC Graphic adheres to the BIC Graphic Code of Conduct with respect to all of its facilities (see below for details).
    2. BIC Graphic requires all of its suppliers to adhere to the BIC Graphic Code of Conduct with respect to their operations.
    3. BIC Graphic’s Asian offices have personnel that have been professionally trained by a highly respected global audit firm to conduct social compliance audits of all of BIC Graphic’s suppliers in Asia.
    4. BIC Graphic’s policy is as follows:

    - Finished product Suppliers located in a country designated as Not Free or Part Free by Freedom House must sign the BIC Code of Conduct every 3 years and be audited by BIC Graphic Asia or a 3rd party audit firm every 3 years.

    - Finished product Suppliers located in any other country must sign the BIC Code of Conduct every 3 years.

  6. 1. Statement of Principles

    BIC Graphic a special place to work, with an atmosphere of mutual respect and professionalism. BIC Graphic and its finished product manufacturers have a responsibility to uphold these principles by creating an atmosphere in which each employee knows that he/she is valued as an individual and treated with respect and professionalism.The BIC Graphic Code of Conduct (“Code of Conduct”) enables us to conduct our business, source products and manage our supply chain in a manner that is both profitable and socially responsible.  

    Implementation of this Code of Conduct enables BIC Graphic to continually improve performance on worker’s rights, labor standards, work place safety and other human rights issues integral to the production process and the overall supply chain.

    Compliance with this Code of Conduct is mandatory for all BIC Graphic entities (collectively, “BIC Graphic”) and for all BIC Graphic finished product suppliers (“Suppliers”).  Further, as a fundamental part of our Code of Conduct, we align our practices to the ETI Base Code and expect the same of our Suppliers.  BIC Graphic reserves the right to immediately terminate its business relationship and cancel all orders with any Supplier or supply chain partner who does not comply with this Code of Conduct.

    2. Work Environment 

    BIC Graphic is committed to treating all its employees with dignity and respect and providing its employees with a safe, healthy, clean and well‐lit work environment including appropriate and adequate facilities and protection from hazardous materials or conditions. BIC Graphic expects its Suppliers to maintain the same standards in their factories and operations. BIC Graphic and its Suppliers must comply with all applicable national, regional, state and local laws, rules and regulations (collectively, “Laws”) governing labor and employment practices and working conditions. If housing is provided for employees, all housing must be maintained in a clean and safe fashion. BIC Graphic strictly forbids the use of cruel and unusual disciplinary practices in the workplace.

    3. Engage in Fair and Ethical Employment Practices

    Fair Wages: BIC Graphic and its Suppliers must fairly compensate their employees by providing wages, benefits and reasonable working hours in compliance with all Laws of the countries in which BIC Graphic and its Suppliers operate a business. Every worker shall have the right to compensation for a regular work week that is sufficient to meet the worker’s basic needs and provide some discretionary income. BIC Graphic and its Suppliers must compensate their employees at a rate equal to, or greater than, the prevailing local minimum wage, including piece rate workers. In addition to their compensation for regular hours of work, BIC Graphic and its Suppliers should compensate employees for overtime hours at the premium rate required by applicable Law.  

    Working Hours:  No employee shall be required to work more than the regular and overtime hours prescribed by applicable Law.  The regular work week shall not exceed 48 hours.  Employers shall allow workers at least 24 consecutive hours of rest in every seven-day period. Other than in exceptional circumstances, the sum of regular and overtime hours in a week shall not exceed 60 hours.

    Child Labor: BIC Graphic will not accept the use of child labor in its operations under any circumstances and will not purchase product(s) from any contract manufacturer that uses child labor. In determining whether a laborer is a “child,” BIC Graphic will refer to the local legal minimum age for employment or the age for completing compulsory education in the country of manufacture. However, the minimum age shall never be younger than 15 years of age. Although BIC Graphic strictly prohibits the use of child labor, BIC Graphic supports the development of legitimate workplace apprenticeship programs for the educational benefit of younger people.

    Forced or Compulsory Labor: BIC Graphic will not support trafficking in human beings or accept the use of forced, compulsory, bonded, indentured or prison labor in its operations under any circumstances and will not purchase product(s) from any contract manufacturer or utilize any supply chain partner that supports trafficking in human beings or utilizes forced, compulsory, bonded, indentured or prison labor. Every employee must be a voluntary worker with the freedom to leave the workplace outside of work hours and terminate employment at any time without penalty after notice of reasonable length. Forced prison labor, or work against the will of an employee, including work required as a means of political coercion or punishment for expression of political views is strictly forbidden. No employee shall be subject to any form of harsh or inhumane treatment, corporal punishment, threats of physical or sexual violence or abuse, or other forms of psychological or physical harassment, intimidation, abuse, coercion or sanctions that result in wage deductions, reductions in benefits or compulsory labor. No part of an employee’s salary, benefits, property, or documents shall be withheld in order to force such personnel to continue working.

    Discrimination: BIC Graphic employs workers based upon their ability to perform the applicable job responsibilities, not on the basis of personal characteristics, beliefs or any form of discrimination and expects its Suppliers to employ their workers on the same basis. BIC Graphic and its Suppliers shall comply with all anti‐discrimination Laws.

    Freedom of Association: BIC Graphic respects the rights of employees to associate, organize and bargain collectively in a lawful and peaceful manner, without penalty or interference, and expects its Suppliers to respect those same rights.

    Legal Compliance: BIC Graphic and its Suppliers shall comply with the Laws of the country in which in which BIC Graphic and/or its Suppliers are doing business. BIC Graphic and its Suppliers shall comply with all applicable export and import Laws. Necessary invoices and required documentation must be provided in compliance with applicable Laws. All merchandise shall be accurately and clearly marked with its country of origin in compliance with applicable Laws. 

    4. Animal Testing

    BIC Graphic is committed to providing consumers with the highest quality products that comply with all applicable product safety standards and Laws. BIC Graphic will not purchase products from Suppliers that use animal testing as part of their product development and production. If a BIC Graphic Supplier believes that alternative testing cannot provide sufficient assurance that a product is safe for consumer use, it should advise BIC Graphic in writing. 

    5. Environment, Health and Safety

    BIC Graphic has maintained a long standing commitment to protect the environment and safeguard the health and welfare of its employees, neighbors and consumers.  BIC Graphic recognizes that nearly every aspect of a manufacturing business has the potential to impact the environment, human health and safety. It is BIC Graphic’s responsibility to minimize those impacts and develop solutions that protect people and the environment and allow BIC Graphic to maintain the product quality and value that consumers expect. BIC Graphic’s approach is to collaborate with its employees, Suppliers, carriers, customers and consumers to identify, assess and minimize the environmental, health and safety impacts resulting from BIC Graphic’s manufacturing and supply chain operations and the manufacturing and supply chain operations of BIC Graphic’s Suppliers. 

    6. Monitor Compliance

    BIC Graphic conducts regular assessments of its facilities and the facilities of its Suppliers to ensure compliance with this Code of Conduct. All BIC Graphic Suppliers will authorize BIC Graphic’s independent third party monitor to inspect their facilities to ensure compliance with this Code of Conduct. 

    7. Publication

    BIC Graphic and its Suppliers will take appropriate steps to ensure that the provisions of this Code of Conduct are communicated to their employees, including the prominent posting of a copy of this Code of Conduct, in the local language and in a place readily accessible to their employees, at all times.

    8. Certification

    The BIC Graphic Code of Conduct clearly states BIC Graphic’s commitment to legal, ethical and appropriate working conditions worldwide. The undersigned authorized representative of the below‐named Company has read the standards described in the BIC Graphic Code of Conduct and understands that a continuing business relationship with BIC Graphic is dependent upon adherence to the standards set forth therein. Any failure to follow these standards may result in the cancellation by BIC Graphic of outstanding purchase orders, refusal by BIC Graphic to accept delivery of merchandise and the termination of BIC Graphic’s business relationship with you.

  7. In accordance with Federal law Trafficking Victims Program (TVPA & TVPRA 2000/2005/2008/2013) and California State law California Transparency in Supply Chain Act of 2010:

    BIC Graphic will not support trafficking in human beings or accept the use of forced compulsory, bonded, indentured or prison labor (collectively, “Forced Labor”) in its operations under any circumstances and will not purchase product(s) from any contract manufacturer or utilize any supply chain partner that supports trafficking in human beings or utilizes Forced Labor. Every employee must be a voluntary worker with the freedom to leave the workplace outside of work hours and terminate employment at any time without penalty after notice of reasonable length. Forced Labor or work or punishment for expression of political views is strictly forbidden. No employee shall be subject to any form of harsh or inhumane treatment, corporal punishment, threats of physical or sexual violence, or other forms of psychological or physical harassment, intimidation, abuse, coercion or sanctions that result in wage deductions, reductions in benefits or Forced Labor. No part of an employee’s salary, benefits, property, or documents shall be withheld in order to force an employee to continue working.

    BIC Graphic pre-qualifies proposed new suppliers with in-person social compliance, supply chain security and manufacturing capacity audits. BIC Graphic’s affiliate, Graphic Advertising & Promotional Products Asia Limited, maintains offices in Hong Kong and Shenzhen, China (“BIC Graphic Asia”). BIC Graphic Asia employs approximately 50 people who regularly conduct audits, quality inspections and on-site business meetings with suppliers. They are trained to look for evidence of human trafficking and slavery.

    BIC Graphic suppliers are required to sign the BIC Graphic Code of Conduct and adhere to those standards. Integrity is a hallmark of BIC Graphic’s supplier partners who are all well informed of BIC Graphic’s zero tolerance policy with respect to Forced Labor, human trafficking and slavery.

    UK Modern Slavery Act (“MSA”) Statement

    BIC Graphic is committed to good corporate citizenship and the highest ethical standards.  To fulfill these requirements, BIC Graphic has established and maintains systems and controls to ensure that slavery and related human trafficking do not form part of the supply chain.

  8. The Dodd-Frank Wall Street Reform and Consumer Protection Act (the “Dodd-Frank Act”) requires companies that are registered with the Securities & Exchange Commission (the “SEC”) to report their use of Conflict Minerals on an annual basis. Conflict Minerals consists of Tantalum, Tin, Tungsten and Gold if mined in the Democratic Republic of the Congo and/or any of its adjoining countries (Central African Republic, South Sudan, Uganda, Rwanda, Burundi, Tanzania, Zambia, Angola and Republic of the Congo). Congress’ main purpose in enacting the Dodd-Frank Act is to inhibit the ability of armed groups in these countries to fund their activities by exploiting the global trade in these minerals. While BIC Graphic is not registered with the SEC and therefore not covered by the Dodd-Frank Act, we will nonetheless assist our customers who are covered by the Dodd-Frank Act with their reporting obligations.

  9. BIC Graphic is C-TPAT Tier II certified by US Customs. The C-TPAT program is designed by US Customs to work in partnership with industry to protect against terrorist activities, drug and weapons smuggling and illegal immigration. BIC Graphic suppliers are audited for supply chain security and are instructed on measures they must take to improve upon their security systems and practices.

  10. BIC Graphic does NOT tolerate bribery or corruption 

    BIC Graphic prohibits bribery and corruption in any form—everywhere we operate—upholding our reputation for integrity.

    Scope of application of this policy

    Compliance with this policy is mandatory for all BIC Graphic employees, officers, directors, subsidiaries, and affiliate companies. This policy also applies to any third-party contractors, dealers, consultants, and any other agents or person acting for or on BIC Graphic’s behalf.


    There is no place in our business for offering or receiving any form of improper payment, improper advantage, or bribe. Even if a bribe is offered but not accepted, or promised and never delivered, it creates an environment in which bribery and corruption seem acceptable. Bribery is prohibited by U.S. laws as well as other laws that might apply to BIC Graphic and its employees and we are committed to observing the standards of conduct set forth in the United States Foreign Corrupt Practices Act and the applicable Anti-Corruption and Anti-Money laundering laws of the countries in which we operate.  These laws often impose serious penalties on companies and individuals that violate them, including significant fines and, in the case of individuals, imprisonment.

    What is a bribe?

    A bribe can be any benefit, advantage, or thing of value offered, promised, given, or received to encourage someone to do something dishonest, illegal, or inconsistent with the proper performance of their role. Corruption is the abuse of entrusted power for private gain, which can take many forms ranging from a minor use of influence to institutionalized bribery.


    Dealings with Government Officials

    We must never offer, promise, or give any benefit to any Government Officials, directly or indirectly, with the intention of influencing them in their work or in an attempt to obtain or retain business or a business advantage. This policy forbids providing even “facilitating” or “grease” payments, small payments, and gifts to Government Officials in order to get them to do something improperly involving their official duties. Even such payments to Government Officials to encourage them to expedite or perform a routine governmental action are strictly prohibited unless expedited action or premium processing is available generally and lawful where such payments are made. We should always take great care when we deal with Government Officials or when others deal with them on our behalf because our actions could expose BIC Graphic and the individuals involved to serious penalties. It is important to keep in mind that even persons who are not deemed to be officials under local law may still be considered Government Officials under laws that might apply to BIC Graphic and its employees. To be certain, employees always should consult your local Legal Team whenever there is doubt as to whether an individual is a Government Official.

    Dealing with private entities and people who are not Government Officials

    Most of our business relationships are with private entities and individuals. Even in transactions that do not involve Government Officials, we must be careful to ensure that we act, and are always seen to act, with complete integrity.

    • We must never offer any benefit, advantage, or anything of value to any person who we know is not permitted to receive it, or with any intention to improperly influence any business decision.

    • We should obtain written line manager preapproval before providing or offering anything that we think might improperly affect a business decision, improperly influence a decision maker, or cause the recipients to breach any duties to their employers.

    • We may offer to reimburse reasonable and appropriate travel accommodations, meals, and certain entertainment expenses associated with a legitimate and proper business activity.

    If you have any questions about the appropriateness of any benefit or invitation (given or received), contact your Legal Team.

    Corporate hospitality, gifts, and sponsorship

    Meals, entertainment, and gifts are in many situations an appropriate recognition of a working relationship. They are also considered to be “things of value,” and it is our personal responsibility to always ensure what we offer or accept is not inappropriate or lavish and cannot be misinterpreted. Even entertainment that would otherwise be reasonable is not permitted by this policy if intended to wrongfully influence a participant. Further, remember that simply offering something you know that the recipient may not rightfully accept can in some circumstances be illegal.

    To help us decide what is “appropriate,” these principles below should be followed:

    • Never offer or accept cash or cash equivalents under any circumstances.

    • Only offer gifts that are of modest value and, preferably, display BIC Graphic branding.

    • Only offer or accept entertainment if it is occasional, business-related, and reasonable in the local business context. We must not provide or accept excessive or inappropriate entertainment or create a feeling of obligation, especially if the recipient is a Government Official.

    • The occasional provision of reasonable, ordinary course, hospitality at our facilities is usually appropriate, so long as it is not intended to wrongfully influence a participant and is otherwise consistent with applicable rules, legal, and proper. Special care should be given before providing such hospitality to Government Officials because local laws and rules may preclude doing so.

    Sponsorship involves sponsors agreeing to have their names, services, or products associated with the sponsored organization’s activities for an agreed commercial benefit. Sponsorship is distinct from gifts, entertainment, donations, or contributions.

    Relationships with stakeholders

    We want to develop relationships with stakeholders who share our values and ethical standards as set out in our Code of Ethics and who implement appropriate anti-bribery and anti-corruption procedures. Before you establish a relationship with a new stakeholder on behalf of BIC Graphic, you should satisfy yourself that the stakeholder does not pose a risk of bribery or corruption. If you suspect corruption at any point when making checks or inquiries about a stakeholder, contact your Legal Team.

    Charitable, community, and political contributions

    BIC Graphic is committed to playing an active and positive role in the markets in which we operate; however, charitable, community, and political contributions must never be used as a means to conceal a bribe. If we are asked to provide a charitable contribution or to make a donation, either on BIC Graphic’s behalf or in a personal capacity, we should be very careful, especially if the request has come from a public servant or Government Official, or if the beneficiary is connected to a Government Official. BIC Graphic funds and other group assets may not be used, either directly or indirectly, to benefit political organizations or political candidates. Contact your Legal Team and tax manager to evaluate the tax treatment of a donation agreement.

    Conflicts of interests

    Conflicts of interests arise when a personal interest interferes, or appears to interfere, with the best interests of BIC Graphic. A conflict of interest can develop into a bribery problem when an employee requests, agrees to receive, or does receive something of value that interferes with the employee’s judgment in performing his or her role on behalf of BIC Graphic. We should take great care to keep our personal, political, and charitable activities entirely separate from our work.


    We are all responsible for ensuring compliance with this Policy, BIC Graphic’s Code of Ethics, and all laws and regulations. All managers should ensure their reports receive the guidance and training they need to work in compliance with this Policy and applicable laws. You are expected to communicate the values behind this Policy in your interactions with colleagues and third parties and to take appropriate steps to ensure your third-party stakeholders do not put BIC Graphic at risk of bribery or corruption.

    Record keeping

    Strict laws require our record keeping to be accurate and transparent. We must keep records of all meals, entertainment, travel, gifts, charitable contributions, pre-approval documents, stakeholder checks, and supporting documents. This includes any records we keep in the appropriate BIC Graphic accounting system and training records.

    How does this apply to me?

    • Never offer or accept bribes, including “facilitating payments” or other improper payments.

    • Never offer or accept any gift, benefit, payment or other advantage in return for anything improper.

    • Never do anything to encourage or allow someone else to breach these principles and related guidance.

    Monitoring and reporting

    To avoid breaches of anti-bribery and corruption laws, follow this Policy and do not be afraid to ask questions—contact your Legal Team. Remember, bribery is illegal, so you should always report any actual or suspected breach to your Legal Team, even if BIC Graphic is not directly involved.

    Breaches of this policy will be dealt with under BIC Graphic’s disciplinary policies.

    Contacts and further information

    Seek help and guidance on all issues relating to the Code of Ethics and BIC Graphic policies from your HR and Legal Teams.

    This Policy was last reviewed and updated in December 2018.

  11. Without ethics nothing can be sustained. Ethics is at the heart of BIC Graphic’s philosophy and has been the cornerstone of the basic business principles which drive BIC Graphic’s success. BIC Graphic’s reputation for integrity, honesty and fair dealing was well established long before our Code of Ethics was written. Our goal is to build relationships with all of our stakeholders – employees, customers, suppliers, shareholders, and regulators – based on honesty, trust and respect. Ethics is based on standards and principles of behavior endorsed, supported, and practiced by all of our managers and employees around the world. The purpose of this Code is to formalize the fundamental ethical principles of BIC Graphic so that everyone can refer to it and conform to it in all circumstances. The goal is to build and maintain a culture within BIC Graphic that does the right thing day in and day out. The standards are not intended to be exhaustive but rather represent essential reference points for all BIC Graphic employees and partners. Throughout the Code, questions provide guidance for identifying when an ethical issue may be present and require action. It is everyone’s responsibility to abide by and practice these standards on a daily basis, thereby maintaining and enhancing BIC Graphic’s reputation as a trustworthy partner. Inherent in the standards is our responsibility to reject any attitude or behavior contrary to the Code. The Code of Ethics does not address all workplace conduct. BIC Graphic maintains additional policies and guidelines that may provide additional guidance. Any questions, concerns, or issues regarding the Code of Ethics should be addressed with your HR and/or Legal Teams.

    Fundamental Human Rights

    BIC Graphic abides by the international labor organization conventions regarding the protection of workers and the ban on forced labor and child labor. BIC Graphic requires its suppliers to do the same.

    BIC Graphic employs workers based on ability to perform a job task and does not discriminate, for any reason whatsoever, in the recruitment of employees, in the development of skills and careers and more generally in relationships at work.

    BIC Graphic does not tolerate any form of moral or sexual harassment and prohibits any behavior likely to create an intimidating, hostile or offensive work environment.

    Respect for the Environment

    BIC Graphic has enacted an environment, health and safety policy, continually monitors its application and asks that all its suppliers and contractors operating on BIC Graphic sites exercise the same vigilance.

    BIC Graphic’s focus is on the continual improvement of the environmental performance of our factories. In particular, BIC Graphic strives to minimize the impacts of its operations.

    When designing and manufacturing its products, BIC Graphic continually strives to utilize innovative technical solutions to minimize the impact on the environment.

    In addition, BIC Graphic actively promotes environmentally friendly practices in all of our offices and encourages each of our employees to adopt behaviors to avoid wasting energy and natural resources.

    Listening and Communicating

    BIC Graphic is committed to developing relationships and celebrating diversity throughout the organization based on respect and trust.

    BIC Graphic intends to foster and maintain a responsible social dialogue. BIC Graphic is committed to making complete, timely and accurate disclosures to our employees. The Company has a responsibility, both legally and ethically, to communicate effectively and candidly with our employees.

    Compliance with the Law

    BIC Graphic complies with all laws and regulations and asks its suppliers to do the same.

    BIC Graphic is committed to complying with all applicable anti– corruption laws and regulations. Many governments have implemented laws to prohibit the making or offering of bribes and facilitation payments to government officials in connection with obtaining or retaining business, influencing any official act or securing any other improper advantage.

    In particular, all employees are instructed to strictly respect all laws and regulations relating to, among other things, anti- corruption, competition, intellectual property, labor and employment, safety, health, and the protection of the environment.

    BIC Graphic encourages its employees to be involved in their local community, however, BIC Graphic funds and other group assets may not be used, either directly or indirectly, to benefit political organizations or political candidates. A political contribution includes both direct (i.e., money) and in-kind contributions. In-kind contributions include the purchase of fundraising tickets, contribution of products, volunteer work by employees within normal business hours and the use of BIC Graphic facilities for fundraising or political purposes.

    The operational responsibility for BIC Graphic’s relationships with public authorities and institutions is delegated to a small number of specifically identified senior managers, who have been named to represent BIC Graphic.

    Conflicts of Interest

    Each employee must avoid any situation where a conflict exists between BIC Graphic’s interests and the personal interests of the employee or his/her family members. 

    In particular, each employee is prohibited from:

    • Acquiring any ownership or other financial interest in any competitor, supplier or customer that would conflict with his/ her responsibilities to BIC Graphic.

    • Conducting any external business or professional activity that would be contrary to the interests of BIC Graphic, including with a competitor, supplier, or customer.

    Protection of BIC Graphic’s Assets

    Each employee is responsible for protecting BIC Graphic’s confidential information and trade secrets to avoid disclosure to competitors, customers, suppliers and employees who do not have a valid business reason for obtaining the information.

    Each employee is prohibited from disclosing to third parties, or to other employees within BIC Graphic who have no business reason to receive it, confidential business information to which he/she has access.

    Each employee is responsible for ensuring that the information he/she generates is always accurate, reliable and shared with all appropriate employees.

    Professional Commitment

    Each employee shall conduct himself/herself with the highest degree of professionalism and collaboration, thereby helping to ensure that BIC Graphic standards are maintained.

    Each employee shall be committed to fostering a climate of trust and close collaboration with his/her colleagues and shall not condone or tolerate any discriminatory, offensive or inappropriate behavior.

    Each employee shall be committed to delivering quality work in a timely manner and shall always be aware of the needs and expectations of his/her colleagues.

    Relationship with Stakeholders

    Each employee must follow the principles of integrity, honesty and fair dealing in all of his/her dealings with BIC Graphic’s stakeholders.

    When dealing with customers, suppliers and other third parties, each employee is committed to conducting himself/herself objectively and only in the best interests of BIC Graphic.

    Each employee is prohibited from soliciting or accepting, directly or indirectly, any gifts with an economic value that exceed acceptable business practices.

    No employee shall condone the use of BIC Graphic funds, assets or property for any unlawful or improper purpose. In particular, BIC Graphic does not tolerate any form of bribery and corruption.

    Duty to Report

    Each employee is responsible for bringing to the company’s attention any circumstances which the employee believes in good faith may constitute a violation of the BIC Graphic Code of Ethics. BIC Graphic considers the failure to discharge this responsibility may be as serious as the violation itself.  Information regarding potential violations or violations should be reported to your supervisor, Human Resources Representative and/or the Vice President - Legal. The Company will make every effort to see that employees giving information in confidence are protected.

    No Retaliation

    Threats or acts of retaliation or retribution against employees who make use of the complaint procedure or assist in an investigation will not be tolerated.  Use the procedure described above to report any such retaliatory actions.

    Disciplinary Action

    Deviation from the policies set forth in the BIC Graphic Code of Ethics is considered a serious infraction and may result in disciplinary action by BIC Graphic up to and including termination and, if appropriate, prosecution.

    This Policy was last reviewed and updated in December 2018.

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