Sustainability Statement Pollution (E2) 04 4.3.5.2 Prioritizing actions and resources A highly skilled, multi-disciplinary team is in place to actively monitor the latest chemicals-related regulatory and scientific developments. This supports a prioritization process that focuses diagnostics, strategic recommendations and the Group’s R&D programs on the chemicals with the highest HSE risks. This process prioritizing the highest risk chemicals and the mitigation of their risks is currently being formalized. It covers the chemical raw materials used to manufacture tires, as well as their impurities and/or their by-products generated during manufacture or use. In addition, in 2024, a study was undertaken to determine the need for digital tools to support the HSE risk prioritization and mitigation process, with the same scope of application. The necessary resources and timeframes are currently being determined. As regards substances of concern or very high concern (SOC/ SVHC), the Group does not currently have any targets for preventing and reducing their use. The continually changing state of knowledge concerning the toxicology and ecotoxicology of these substances makes it difficult to set absolute targets. The Group is stepping up its R&D commitment to identify and develop replacements wherever possible, in line with the European Commission’s objectives. Note, however, that every new raw material used in tire manufacturing is subject to approval by the in-house teams, which guarantees that by default, it does not contain any substance listed in REACH annexes XIV and XVII or on the REACH candidate list. 4.3.6 A HOLISTIC UNDERSTANDING OF POLLUTION IN THE UPSTREAM VALUE CHAIN 4.3.6.1 Framework policies: Sustainable and responsible purchasing, Natural rubber and Pollution In the Group’s upstream value chain, the Group’s responsible and sustainable Purchasing Policy, supported by the Supplier Code of Conduct, specifies a number of prerequisites and recommendations, covering such areas as the preservation of ecosystems, the reduction and management of waste and packaging, and the mandatory disclosure of REACH information and SVHC certificates. The natural rubber policy is more closely focused on the impact of fertilizer and pesticide use in rubber tree farming, with one of its five sections in particular addressing the judicious use of pesticides, chemical fertilizers and other chemicals. Neither of these documents target any pollutants or substances in particular, apart from SVHCs. 4.3.6.2 Initiatives and a target on pesticide use Michelin has deployed the following resources to measure and mitigate the negative impacts of pollution: n The RubberWay application(1), used to map risks in the natural rubber supply chain, includes questions concerning the use of pesticides and other chemicals, the management of chemical waste, and the odor-abatement treatment of gaseous effluent from natural rubber processing plants; n projects undertaken in the natural rubber supply chain to develop the skills of village smallholders include environmental impact training with a focus on pesticides and waste; n annual or biennial audits of natural rubber processing plants performed as part of quality system assessments address such environmental issues as odors, wastewater treatment and waste management. If the results fall short of compliance, a remedial action plan is requested; n third-party assessments (usually desktop reviews) of the CSR maturity of the leading Tier 1 suppliers include questions on pollution. If the answers fall short of compliance, action plans are requested; n on-site audits of raw material suppliers conducted as part of supplier quality system assessments include questions relating to environmental policies, regulations and waste management. If the answers fall short of compliance, remedial action plans are requested. In 2024, the Group also prepared a biodiversity questionnaire for its main suppliers of raw materials other than natural rubber, whose pilot deployment will be launched in 2025. It includes a series of pollution-related questions to determine how well the issue is managed by the supplier. (1) See section 4.9 Workers in the value chain (S2) for a presentation of the RubberWay application. 228 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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