Sustainability Statement Business conduct (G1) 04 4.11.2 BUSINESS CONDUCT POLICIES AND CORPORATE CULTURE The management of ethical risks and the fight against corruption are supported by two fundamental reference documents, respectively the Michelin Code of Ethics and the Anti-Corruption Code of Conduct. Both are prefaced by a statement from the Managers emphasizing the Group’s commitment to ethics, which is based on the ethical behavior of each employee, acting as an “ambassador of Michelin’s values.” Both may be downloaded from the Code of Ethics website(1), the corporate website(2) and the Purchasing website(3). The Regional President is responsible for ensuring that the Codes are properly applied everywhere in his or her geographical remit. In practice, the Codes are deployed by the Regional General Counsels and/or Compliance Officers, overseen by the Regional Ethics Committees and the Group Ethics Committee, which is chaired by the General Manager and Chief Financial Officer. A deployment status report is presented to the Regional Ethics Committees and included in the annual reports submitted by each Region to the Group Ethics Operational Committee. Internal control procedures are performed to verify that the Codes have been distributed and accessible to every employee in the Region or business unit, with a particular focus on employees in at-risk countries and newly acquired companies. Other internal audits, focused either on Code deployment or more general issues, may also be carried out. 4.11.2.1 The Michelin Code of Ethics Subtitled “Acting Ethically Every Day,” the Michelin Code of Ethics reviews the Group’s fundamental values (respect for facts, respect for people, respect for customers, respect for shareholders and respect for the environment) and describes the Group’s ethical principles and compliance procedures. It sets out the guidelines governing employee and stakeholder decisions, with practical advice on how to respond to the most frequently encountered situations (“Dos and Don’ts”), and specifies the behaviors to adopt in typical situations for each work environment. Translated into 21 languages, the Code of Ethics was reviewed and expanded in 2021, in particular to strengthen the Group’s commitments in areas like human rights and the environment, while responding more effectively to employee questions and making it easier to understand. The Code of Ethics addresses the business conduct risks related to the giving or receiving of gifts and invitations, international trade and export controls, competition law, conflicts of interest, charitable and political donations, stock exchange regulations/ insider trading, anti-fraud/anti-corruption, privacy and personal data protection, supplier relations and compliance with laws and regulations. The Code applies to all employees and to any person working on Group sites or acting on behalf of a Group unit, anywhere in the world. The Group also encourages its customers, suppliers and other partners to adhere to the provisions of the Code, and in many cases, compliance is a prerequisite for doing business with the Group. The Group supports ongoing Code deployment and compliance with regular, dedicated videos, events and other forms of communication. The Code is also distributed to new hires, who receive in-person and online training in ethics issues. Information campaigns are also organized for suppliers and customers. 4.11.2.2 The Anti-Corruption Code of Conduct To mitigate the risks of corruption, in 2015, the Group introduced an Anti-Corruption Code of Conduct applicable to all employees and agents (i.e., third parties acting in the name and on behalf of Michelin). Updated in 2020, it attests to the Group’s commitment to deploying a policy of zero-tolerance for any form of corruption or bribery. The Group also encourages its customers, suppliers and partners to adhere to the principles of the Code, through (i) contractual clauses inserted in their contracts referring to the Code and the Michelin Purchasing Principles and specifying the Group’s anti-corruption compliance requirements and expectations; and (ii) newsletters. The Code is designed to raise employee awareness of actions that could be construed as bribery or corruption, by providing examples and indicating the course of action when confronted with such events or situations. In particular, it deals with such issues as bribes, kickbacks and payoffs, the use of agents and brokers, payments for favors or other inducements, charitable or political contributions, gifts and invitations. (1) https://ethique.michelin.com/en/. (2) https://michelin.com/. (3) https://purchasing.michelin.com/. 288 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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