4 _269 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report 4.1.4.1 a) Establishing a global ethical framework Code of Ethics The Group’s ethical standards are expressed in the Michelin Code of Ethics, which applies to all Group employees without exception, as well as to people working on Group sites or on behalf of a Group entity. Initially published in 2010 and updated in 2014 and 2020, the Code of Ethics was reviewed and expanded in 2021, in particular to strengthen the Group’s commitments in areas like human rights and the environment, while responding more effectively to employee questions and making the Code easier to read. Specifically, the new Code of Ethics: ● reiterates the Group’s values and fundamental guiding principles; ● tells employees how to respond to the most frequently encountered situations; ● clearly expresses the behaviors to adopt in line with Group values and procedures (“Dos/Don’ts” section); ● deals with more complex situations and explains the course of action to be taken (“Practical Cases” section); ● provides a list of experts to consult in case of doubts (“Whom to contact” section); ● proposes a list of additional documents to explore issues in more depth (“References” section). The principles of the Code of Ethics are described in four categories: “At Work”, “Doing Business”, “External Interactions” and “My Work and the Environment”. They cover 25 issues, some of which are addressed by specific procedures presented elsewhere. Personal data protection, for example, is covered by more detailed guidelines in the Group Personal Data Protection Directive and its supporting documents. Now subtitled “Acting Ethically Every Day,” the Code of Ethics is prefaced by a statement from the Managers emphasizing the Group’s commitment to ethics, which is based on the ethical behavior of each employee, acting as an “ambassador of Michelin’s values.” Translated into 21 languages, the Code can be downloaded from the Group’s intranet sites and a dedicated website (https://ethique.michelin.com/en/). An easier to read digital format is also available in 21 languages, with versions in the other Group languages being finalized. Deployment of the revised 2021 Code of Ethics was supported by dedicated e-learning modules, videos and events organized both by the Group and by the regional organizations in their member countries. Compliance control Compliance with the rules of conduct in the Code of Ethics is ensured through the application of internal procedures and verified during internal control and audit assignments. Internal control procedures specifically focused on ethics and compliance issues are being steadily stepped up across the organization, with the number of audits rising by 20% in 2023 after increasing by 55% in 2022. Alert mechanisms and procedures The Group takes care to conduct all its business activities in an ethical fashion and wants employees and external stakeholders to speak up and report suspected violations of the Michelin Code of Ethics. Since 2021, a single Group-wide whistleblowing system has been deployed in every Group entity, replacing the regional alert mechanisms that had been in place since 2005. Available in 30 languages, the system may be accessed by Group employees, contractor employees and temporary workers, as well as by customers, suppliers, service providers and other outside stakeholders via a hotline and a secure website hosted by an independent company. The system allows whistleblowers to anonymously and confidentially report any behavior, practice or situation that allegedly violates applicable laws, internal procedures or the Group’s values and principles as set out in the Code of Ethics. As stated in the Code, possible violations may also be reported through the following traditional channels: ALERT MECHANISM STAKEHOLDERS All reports are consolidated in the Group’s alert hotline and regularly presented to the Corporate Ethics Committee and the Group Management Committee. In 2023, the Group issued a new Group Whistleblowing Procedure, which provides a transparent, detailed description of the people involved in the whistleblowing system and how alerts are collected and processed. The Procedure is available in 20 languages to all employees and external stakeholders on the Corporate website, the Code of Ethics website (https://ethique.michelin.com) and the Ethics Hotline website. The following chart summarizes the key stages in processing a whistleblowing report. Ethics Hotline (by telephone or online) Legal Affairs Department Ethics Correspondent or Regional Compliance Officer Planning, Prevention and Protection Department Occupational prevention and health office Direct or other manager Personnel Department Employee representative
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