Transparency

Disclosure 103-1 , 103-2, 103-3 Disclosure 417-1

Accessibility to relevant information concerning a product is essential to ensure greater user safety. Furthermore, such accessibility is also key to communicating product characteristics and performance, which must always be stated in a clear, precise and non-misleading manner. RadiciGroup has long worked for transparency in product formulation and communication at all levels:

all Group products must meet the general safety and labelling regulations of the European Union and the laws of the countries where they are produced or sold,

in many cases, the products can also be subjected, on a voluntary basis, to additional safety specifications or provisions, more restrictive than the mandatory provisions in force.

Regarding the Advanced Textile Solutions Business Area, all products comply with the obligations set forth by the REACH regulation. Moreover, yarns with a PA6/PA66 polymer matrix for textile applications are certified to the international Oeko-tex® Standard 100, Annex 6, Class I, while fibres with a PET polymer matrix are certified to Oeko-tex® Standard 100, Annex 4, Class I. Furthermore, in the two-year period 2018-2019, the yarns of the Renycle® (nylon) and Repetable® (polyester) families of products were certified to the Global Recycled Standard (GRS), a certification of the recycled content in products. The GRS includes the Zero Discharge of Hazardous Chemicals (ZDHC) provisions and requires that, for each item sold, a declaration of actual recycled content be provided. The nonwovens with recycled content in the Respunsible® product family were certified as circular products in 2020, according to the International Sustainability and Carbon Certification (ISCC) system. Concerning the Group’s Specialty Chemicals Business Area, all the chemicals produced at the Novara (Italy) and Zeitz (Germany) plants comply with the requirements of the REACH regulation. This European Union regulation was adopted to better protect human health and the environment from the risks of chemical substances. The registration dossiers for the two plants are constantly updated to reflect the findings of current toxicological and ecotoxicological studies, according to the European Chemical Agency (ECHA). Product safety sheets sent to users downstream contain the instructions for correct and safe use. A safety sheet in accordance with REACH provisions is also issued for all products manufactured by the RadiciGroup High Performance Polymers Business Area. Additionally, for all High Performance Polymer products, a REACH Declaration is issued stating the absence of Substances of Very High Concern (SVHC), together with a specific REACH Compliance Statement (1907/2006) attesting to the fact that all the substances contained in the product have been registered or are exempt from registration. A statement is also provided pursuant to EU Directive 2011/65/EU (RoHS) on the restriction of the use of certain hazardous substances in electrical and electronic equipment. Products for the automotive sector come with IATF 16949:2016 certificates. Products that come in contact with food are accompanied by declarations of conformity, as required by the international regulations (EU Regulation 10/2011, FDA, etc.) on materials coming into contact with food. In matters of product environmental communication, the Group’s job is facilitated most of all by the Environmental Product Declarations (EPDs), based on ISO standards and Life Cycle Assessment (LCA) studies, completed and prepared according to the related Product Rules, which aid the Group in maintaining a high level of transparency. In particular, the registered EPDs cover products of the High Performance Polymers BA - Heramid A (PA66), Radilon® S (PA6) and Radilon® A (PA66) - and Advanced Textile Solutions BA - Radifloor® (PA6 and PA66) Bulk Continuous Filament and Refined Yarns. Advanced Textile Solutions also added certifications of compliance to the Global Recycled Standard (GRS) for its nylon recycled products (Renycle®) and polyester recycled products (Repetable®), and International Sustainability and Carbon Certification (ISCC PLUS) covering traceability for circular nonwovens.

Disclosure 417-12, 417-3 Thanks to the effort spent on environmental labelling and communication, in the reporting period no Group company reported either incidents of non-compliance concerning product and service information and labelling, or incidents of non-compliance with rules concerning marketing communications.