_64 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 2 RISK MANAGEMENT Cross-functional risk management procedures 2.2.3 Group compliance team and network The role of the Chief Compliance Officer, as well as the organization of her corporate-level team (the Compliance Support Group in the Group’s Corporate Legal Department) and the Compliance network, are presented in Chapter 4, section 4.1.4 below. The Group pays particular attention to the risk of ethics violations or failures to comply with laws and regulations. Ethics and compliance-related internal control audits are performed by the Compliance Support Group and led by the Chief Compliance Officer. The Business Ethics risk family is governed by the Ethics Committee, chaired by the General Manager. In 2023, the Chief Compliance Officer oversaw the Group-wide deployment of new guidelines on managing fraud risk. In 2024, the Compliance Support Group, the Corporate Finance Department and the Group Internal Control Department will work together to track (i) the key performance indicators of the Internal Control Compliance Rate in the Purchasing, Sales and Accounting processes; and (ii) the progress rate of the deployed action plans. After increasing by 55% in 2022, the number of Compliance‑related internal control projects (level 1 controls and level 2 tests) rose by another 20% in 2023. These controls and tests primarily covered the following areas: ● combating corruption and influence peddling: deployment of the Code of Ethics and the Anti-Corruption Code of Practice, training for all exposed employees and other stakeholders, tracking the third-party due diligence system, gifts and invitations, and regular internal audits of systems in place (four anti-corruption audits performed in 2023); ● compliance with competition rules: deployment of the dedicated competition compliance program; ● protection of personal data: deployment of the Group protection of personal data directive, compliance with the Binding Corporate Rules concerning the transfer of personal data and the processing of health data; ● processing Ethics Hotline alerts: audits of employee awareness and deployment of the various channels in the Group's whistleblowing system, compliance with the internal procedure for reporting and processing cases of demonstrated non-compliance and implementation of the action plans, particularly as concerns the application of disciplinary measures. In addition, a follow-up audit of harassment risks was carried out in 2023. Tests are performed by the network of internal controllers, alongside members of the Compliance Support Group. 2.2.4 Crisis management processes Another cross-functional process concerns crisis management. The Group sees crisis situations emerge regularly in the course of its operations. Given its size, the nature of its manufacturing and commercial activities and its environmental and social responsibility, Michelin is exposed to the risk of crises that could affect its business, its customers and its reputation. To foresee, plan for and effectively respond to any such events, a crisis management system is in place and led jointly by the Corporate Internal Audit, Risk Management, Internal Control and Quality Department and the Corporate Anticipation Prevention and Protection Department. The system’s underlying processes are regularly updated to ensure maximum effectiveness and responsiveness. It is deployed among the various management teams through simulation exercises and appropriate training seminars. The system, which was amply stress-tested during recent crises, is supported by a network of trained crisis managers at every level of the organization, providing dense coverage in units across the entire Group. and demonstrating the system’s effectiveness and validity.
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