_270 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report ALERT MECHANISM STAKEHOLDERS Possible infringements or violations of Michelin’s values, applicable legislation or the Code of Ethics may be reported through a variety of internal whistleblowing channels: ● the Ethics Hotline (by telephone or online), ● a direct or other manager, ● the occupational prevention and health office, ● an employee representative, ● the Legal Affairs Department, ● the Personnel Department, ● the Planning, Prevention and Protection Department, ● the Ethics Correspondent or Regional Compliance Officer. Reports are analyzed and processed by authorized personnel in accordance with the Group Whistleblowing Procedure and the Group-wide internal investigation procedure defined by the Corporate Legal Department and the Corporate Planning, Prevention and Protection Department. Based on the reported information, the regional Ethics Committees concerned decide if the alert is admissible and if it warrants an internal investigation. If the investigation substantiates the alleged violations, the Committees define and deploy action plans with remedial measures and/or disciplinary sanctions up to and including dismissal. In 2023, a total of 2,233 suspected cases of non-compliance(1) were reported across the Group, but not all of them were substantiated as violations of the Code of Ethics. The figure corresponds to the total consolidated number of reports received directly on the Ethics Hotline or through traditional whistleblowing channels. Of the 1,472 processed reports, 34% turned out to be unfounded, 8% lacked sufficient information for an investigation to be launched and 56% resulted in remedial and disciplinary measures including dismissals. Of the total, 2% were duplicates. Among the cases resulting in remedial and disciplinary action, some concerned situations where non-compliance was not substantiated, but which were still addressed with measures to improve control procedures or internal processes. (1) Total consolidated number of reports received directly on the ethics hotline or through traditional reporting channels. MAIN STEPS FOR PROCESSING AN ALERT Whistleblowers will be informed that their Alert has been received within seven (7) days in the form of a receipt. Alerts will be analyzed for admissibility based on the information received from the Whistleblower. Investigations are done for admissible Alerts, to check whether the allegations are true, based on factual information (interviews, witnesses’ statements, forensic analysis) The investigations’ conclusions are presented to the competent Ethics Committee which will decide on the necessary measures to implement. The Whistleblower, the implicated person and anyone who participated in the Alert’s processing are informed that the investigation has been closed. The situation is monitored after closure to ensure that there is no retaliation and that the corrective measures are implemented. RECEIPT ADMISSIBILITY INVESTIGATOR APPOINTMENT INVESTIGATION DECISION CLOSING FOLLOW UP OF MEASURES AND NO RETALIATION ALERT SENT ALERT RECEIVED INVESTIGATION REPORT COMMITTEE DECISION 6 MONTHS > 1 YEAR LATER
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