_268 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report The CSG takes a holistic, multidisciplinary approach to ethical and compliance risks. Its primary mission is to maintain high-quality protection for the Group and its employees through the creation and deployment of robust compliance programs. It works in close collaboration with the Compliance network and other corporate departments (personnel, audit, internal control, communication, sustainable development & impact, purchasing, etc.). In January 2023, Michelin won the “Best Overall Transparency” award at the 2022 Ethics & Compliance Transparency Awards, organized by Labrador Ethics & Compliance. The award was based on an analysis of 75 objective criteria covering the accessibility, accuracy and comparability of the media made public by listed companies in the SBF 120 index to address ethics and compliance issues, including the Universal Registration Document, the Code of Ethics, the Anti-Corruption Code of Conduct, the Duty of Care plan, ethics and compliance policies and procedures, and the website. 4.1.4.1 Ensuring ethical business practice SDG 16.5 Risk of ethics and compliance violations The Group pays particular attention to the risk of ethics violations or failures to comply with laws and regulations and expects every employee to act consistently with integrity, in respect of the internal and external standards that have underpinned its corporate culture for over a century. Any conduct that runs counter to these values could expose Michelin to the risk of infringing an ethical standard or an applicable law or regulation. Note that the Ethics risk family includes a risk factor specifically addressing the social responsibility of Group suppliers (see section 4.1.4.2). • Ethics Line • Investigations • Internal Control • Third Party Assessment • Risk mapping • Communication plan • Training plan GROUP CHIEF COMPLIANCE OFFICER (CCO) PERSONAL DATA ANTITRUST ENVIRONMENT COMPLIANCE OPERATIONS EXPERTS TOOLS & PROCESSES ETHICS HARASSMENT CORRUPTION HUMAN RIGHTS FRAUD
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