04 Sustainability Statement Workers in the value chain (S2) 4.9.2.2 The Group’s Sustainable Natural Rubber Policy (updated in 2021)(1) Focused on natural rubber procurement, the Sustainable Natural Rubber Policy covers all of Michelin’s own operations, joint ventures and upstream supply chain. It informs management decision-making processes, systems and performance metrics at Group level and in the concerned business units, subsidiaries, affiliates and joint ventures. The first version was drafted in consultation with WWF, while the subsequent version was shaped by extensive input from a wide range of stakeholders, including environmental and human rights NGOs, and complies with the framework defined by the Global Platform for Sustainable Natural Rubber (GPSNR) presented below. The Policy is anchored in five core pillars, including the fundamental pillar of respect for people (upholding human rights, working conditions and the living environment) and the commitment to improving farming practices (initiatives to improve the livelihoods and economic resilience of village smallholders). Its component policies, which address the risks of forced labor, child labor and human trafficking, express the Group’s commitment to: n opposing and combating forced labor and child labor; n mapping its upstream value chain to identify the activities and countries most at risk of human rights violations; n deploying a dedicated mapping exercise for the natural rubber supply chain; n undertaking mitigation initiatives whenever and wherever risks are identified; n maintaining a whistleblowing system open to everyone; n regularly interacting with natural rubber stakeholders and remediating any (1) issues, particularly impacts on free, prior and informed consent or (2) adverse impacts expressed through the grievance mechanism. 4.9.2.3 Complementary elements In addition, since 2012, Michelin has applied a supplier code of conduct (Michelin Purchasing Principles) that mandates compliance with specific forced labor, child labor and employee safety requirements, in line with ILO standards. The Purchasing Principles are translated into many languages and included in contracts and the general terms and conditions. The above-mentioned policy base is aligned with internationally recognized guidelines and principles (UN Guiding Principles on Business and Human Rights; International Labour Organization fundamental conventions). In particular, the Responsible Natural Rubber Policy specifies which UN Sustainable Development Goals it is helping to advance. It was drafted with input from stakeholders, including environmental and human rights NGOs, and has been certified as compliant with the GPSNR framework. To the best of the Group’s knowledge, end 2024, no serious incidents of forced labor or child labor were reported as having occurred in 2024 in the upstream supply chain, either to the Group's ethics hotline or in public reports notified to the Group. 4.9.3 WELL-ESTABLISHED DIALOGUE PROCESSES ADDRESSING THE VIEWPOINTS OF VALUE CHAIN WORKERS The views and opinions of workers in the natural rubber value chain are addressed through three channels: n consultations with stakeholders, in particular environmental and human rights NGOs, both when the Sustainable Natural Rubber Policy is drafted or revised and during the regular meetings held every two years or so. The latter enable participants to review the progress made and, most importantly, to propose new pathways for the years ahead, focusing on the sustainable natural rubber roadmap, metrics and targets. A variety of stakeholders are invited to attend, including NGOs, research organizations like CIRAD (a French government research center that works with developing countries on international agricultural and development issues), customers, suppliers and, beginning in 2025, investors. The fourth meeting will be held in early 2025; n Global Platform for Sustainable Natural Rubber (GPSNR), of which Michelin is a founding member. GPSNR brings together stakeholders from across the natural rubber value chain, including village smallholders, other producers and representatives of civil society, with the participation of a large number of NGOs. It is now leading improvements in the environmental and socio-economic performance of the entire natural rubber industry. GPSNR develops frameworks and standards, organizes working groups to bring together stakeholders and discuss best practices, and designs joint programs to implement practical, measurable solutions. (1) Downloadable from Michelin’s natural rubber website (https://purchasing.michelin.com/fr/caoutchouc-naturel-responsable-et-resilient/) and appended to the Group’s natural rubber purchasing contracts. Michelin actively encourages its suppliers to implement sustainability policies aligned with GPSNR recommendations. 275 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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