_302 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Duty of care plan 4.3 DUTY OF CARE PLAN 4.3.1 Methodology For the seventh year in a row, Michelin has prepared a Duty of Care Plan in compliance with French Act No. 2017-399 of March 27, 2017. It describes all of the risks incurred by the Group and its main subcontractors as regards the environment, health & safety and human rights, along with the measures taken to prevent and mitigate them. For Michelin, the plan is a means to consolidate and strengthen its proactive approach to deploying risk prevention and management processes in these three areas, as well as an opportunity to increasingly deepen, year after year, its due diligence with subcontractors as part of a continuous improvement process. The Duty of Care Plan is fully aligned with the Group’s purpose, values and its commitment to conducting its business responsibly with regard to all its stakeholders, who are discussed in a dedicated section. This commitment is supported by strategic management at the highest level of the Company. The plan is based on the information and initiatives already embedded in the Group’s policies, which underpin its sustainable development commitment. These include the Code of Ethics, the Purchasing Principles, the Supplier Relations Code of Conduct, the Health Policy, the Environment and Prevention General Policy Note, the Employee Relations Policy, the Diversity and Inclusion Policy and the Human Rights Policy. It presents the relevant information disclosed by the Group in its Universal Registration Document, including its Non-Financial Statement and other annual reports. The Group has defined standards of compliance that meet and often exceed prevailing standards and legislation in its host countries. Even when local legislation is not as strict as its own, Michelin continues to require compliance with its highly demanding environmental, health & safety and human rights standards. With respect to international environmental and human rights standards, the Group has pledged to support the UN Global Compact and upholds the UN Guiding Principles on Business and Human Rights, the fundamental conventions of the International Labour Organization and the OECD Guidelines for Multinational Enterprises. These international standards also inform the Duty of Care Plan. In 2023, the Duty of Care Plan was coordinated and updated by the Sustainability and Impact Department, in liaison with the Internal Control, Risk Management, Environment and Prevention, Purchasing, Legal and Employee Relations Departments. It is published in the Universal Registration Document in the form of a concordance table referring more broadly back to the issues addressed in the Sustainable Development Report to avoid repetitions and redundancies and to facilitate comprehension. A comprehensive, fully written, stand-alone Duty of Care Plan may be found on the Group’s corporate website, www.michelin.com. In addition, in 2023, Michelin Germany ensured compliance with recent German duty of care legislation, in particular by posting a statement on its website, assessing risks in Germany-sourced procurement and introducing an internal governance system to prevent and mitigate duty-of-care risks.
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