Sustainability Statement Pollution (E2) 04 4.3.1 IDENTIFYING MATERIAL POLLUTION MATTERS Material pollution matters were identified using life cycle assessments (see section 4.1.5.1 Summary of key policies, above) rather than LEAP (locate, evaluate, assess and prepare) assessments. The related impacts, risks and opportunities may be described as follows: n the use phase is the most impactful, partly because of TRWP emissions: l TRWP generation is influenced by many factors, including tire and vehicle design, road curviness and surface, driver behavior and weather conditions. Since 2010, studies have demonstrated the presence of these particles in the environment and provided an initial assessment of their impact. Projects are also underway to test the effectiveness of potential impact mitigation measures. The current state of industry knowledge has been consolidated in the Tire Industry Project’s white paper(1), l stricter TRWP emissions standards could lead to an increase in product design and new product development OpEx and perhaps CapEx. This could be both a risk as well as an opportunity for an industry leader like Michelin; n raw materials are the second most impactful factor, primarily due to the ecotoxicity of biosourced raw materials stemming from the use of fertilizers and pesticides. Today, the Group’s most widely used biosourced raw material is natural rubber; n the treatment of end-of-life tires (ELTs) was not addressed in the LCAs, but rather in the ELT section of the Environmental Policy(2). The Group is nevertheless aware of the risk of pollution, particularly soil contamination from the leaching of landfilled ELTs; n the production phase has a more limited impact. However, a preliminary assessment points to a risk of emission exceeding the indicated threshold for some substances(3). The following section will discuss air and water emissions from the Group’s manufacturing operations, as well as the use of substances of concern and very high concern in certain tire formulations. While the contributions of substances of concern are insufficiently addressed in current LCA applications, they are nevertheless considered material insofar as some of these substances are used in formulations and/or generated by the Group’s operations. 4.3.2 GENERAL POLICIES RELATED TO POLLUTION Impacts, risks and opportunities are closely intertwined and systemically addressed in pollution prevention and control strategy. In particular, they are covered by the Group’s Environmental Policy, which identifies and assesses pollution risks, some among them are the subject of specific policies or dedicated programs. The riskiest substances are identified and assessed by a Chemical Risk Management Policy that seeks to replace them with substitutes wherever technically feasible. The policy is supported by restrictions on substance use and an HSE approval process for new raw materials. By focusing on eliminating chemical pollution sources in the design stage, Michelin’s approach is helping to abate both industrial pollution from its own operations and diffuse pollution from the use of its products. The section of the Environmental Policy concerning manufacturing sites is designed to mitigate impacts by managing the risks of chronic or accidental pollution, in particular by deploying an ISO 14001-compliant environmental management system. The policy specifies the following process to manage pollution risks: n identify the environmental risks; n attenuate the risks to a tolerable level by reducing them at source or, failing that, treating the pollution (prevention and protection, in normal and faulty operating conditions); n comply with regulations. The policy pays particular attention to emissions of volatile organic compounds (VOCs), which are the main source of air pollution from the Group’s own operations. The Group is committed to ensuring that, by 2050, no organic solvents are used in the production of its tires. While the policy does not yet specifically address the issue of wear and abrasion particles, a dedicated section is being drafted as part of the TRWP program set up in mid-2023. Each pollution-related impact, risk and opportunity is covered in dedicated sections describing the policies, actions and targets for TRWP, air and water pollution in the Group’s own operations, chemicals, and pollution in the upstream value chain. (1) See the TIP white paper on TRWP mitigation, https://tireindustryproject.org/news/tire-industry-project-commitment-to-addressing-tire-and-road-wear-particles/. (2) See section 4.6 Resource use and circular economy (E5), below. (3) There are no chronic releases into the soil from Michelin’s own operations, so this issue is considered immaterial. 222 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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