Sustainability Statement European Taxonomy 04 n Agricultural, mining, aircraft and two-wheel tires are not covered by a labeling regulation and therefore cannot be reported in the Taxonomy, even though they provide an array of customer benefits, including improved energy efficiency and with it, lower CO2 emissions; n Tire-as-a-Service activities: the Group is developing fleet management and other services and solutions that optimize the use and management of vehicle fleets, while improving their fuel/energy efficiency. This activity is not deemed Taxonomy-eligible under CE activity 5.5 because it does not meet the criterion of the service provider retaining ownership of the product. Michelin has not identified any activities eligible for the other three Taxonomy objectives, i.e. the sustainable use and protection of water and marine resources, the prevention and control of pollution, and the protection and restoration of biodiversity and ecosystems. 4.7.3 ASSESSING ALIGNMENT Michelin has assessed the alignment of its activities in 2024, according to the following procedures. Information concerning minimum safeguards is presented in the Sustainability Statement sections dealing with human rights, business ethics and preventing corruption. CCM and CCA activity 3.6 "Manufacture of other lowcarbon technologies" and CE activity 5.1 "Repair, refurbishment and remanufacturing" The chemicals-related Do No Significant Harm (DNSH) principle (“Pollution Prevention and Control” objective) now applies to both the CCM and CCA 3.6 activity and the CE 5.1 activity, after its scope was significantly broadened in 2024 by integrating the criteria described in article 57 of Regulation (EC) 1907(2006) Chemicals play a core role both in Michelin’s tire manufacturing process and in delivering key performance attributes such as safety, endurance and a small environmental footprint. Michelin applies a chemical risk management policy designed to protect human health and the environment (see section 4.3 Pollution (E2)). In particular, prioritized action plans are defined and deployed to restrict the use of the highest-risk chemicals or replace them whenever technically feasible. As in 2023, the policy also addresses substances of very high concern (SVHC) on the Registration, Evaluation, Authorization and restriction of Chemicals (REACH) candidate list. With regard to the applicable criteria for reporting 2024 DNSH to pollution prevention and control data, Michelin cannot realistically and reliably assess compliance with the criterion in the last paragraph of Appendix C (substances with a specific hazard class that could be recognized as SVHC in the future). The text does not provide the conditions for an assessment ensuring data access and comparability (number of substances deemed disproportionate for a DNSH criterion, an unusable, constantly changing Chemical & Labeling database, reference to harmonized and non-harmonized classifications). As a result, and pending clarification of the text by the European Commission, Michelin cannot validate compliance with the DNSH criterion concerning chemicals. According to the Taxonomy principle, an activity’s alignment is based on compliance with three fundamental conditions: substantial contribution to the environmental objective, compliance with DNSH criteria and compliance with minimum social safeguards. Given that the DNSH criteria cannot be met, none of CCM and CCA activity 3.6 or CE activity 5.1 was aligned in 2024. CCM activity 8.2 “Data-driven solutions for GHG emission reductions” In the case of CCM activity 8.2, as in the prior year, the Group has not disclosed the aligned proportion because (i) the activity is not deemed sufficiently material (less than 3% of sales); and (ii) there is a lack of data to demonstrate alignment with the criterion defined by the European Taxonomy(1). (1) Concerning materiality, see the answer to question 13 in Commission notice C/2023/305 of October 20, 2023. 260 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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