04 Sustainability Statement Business conduct (G1) The Anti-Corruption Compliance Program (ACCP) Impelled by the commitment of the Managers, in 2018 Michelin introduced an Anti-Corruption Compliance Program based on the provisions of France’s Sapin II Act. Supported by a Group standards manual, it was approved by the Group Ethics Committee in September 2018 then updated and re-approved by the Group Ethics Committee in July 2021. Any new updates are now approved by Group Compliance and sent to the Group Ethics Committee for information. Building on the provisions of France’s Sapin II Act, the Michelin Program is backed by: n Top management’s strong commitment to the Group’s policy of zero-tolerance for corruption and influence peddling; n a corporate compliance team (CSG) and local relay officers in the Regions; n a corruption risk map based on Sapin II standards and the recommendations of the French Anti-Corruption Agency, to identify at-risk operations, processes and countries and determine the mitigation measures to be deployed; n mechanisms for assessing third parties with which the Group works or wishes to work, based on the findings of the corruption risk mapping; n a Code of Ethics addressing the fight against corruption, a dedicated Anti-Corruption Code of Conduct specifying the procedures to be followed based on real-world examples, and a communication plan; n an awareness-building program for all managers and employees and a stepped-up training plan for the ones most exposed to corruption risks; n a whistleblowing hotline accessible to all Group employees and stakeholders (customers, suppliers, NGOs, etc.); n control procedures (anti-corruption accounting audits, internal controls and audits); n a system for tracking disciplinary measures taken in response to confirmed cases of corruption or influence peddling. Each Regional President is responsible for managing corruption risks in all the activities and operations in his or her geographical remit, whether they arise from entities or companies associated with the Region, any other entity or company, or any person acting on behalf of a Group entity or company. Regional deployment of the Anti-Corruption Compliance Program and compliance with its principles are overseen by the Regional General Counsels and Regional Compliance Officers. Any new company joining the Michelin Group, regardless of its business, size, industry or geographic location, must embrace the Group’s ethical principles and values, including the Code of Ethics, the Anti-Corruption Code of Conduct and the AntiCorruption Compliance Program and all other corruption risk management policies and guidelines no later than twelve months following the closing of the acquisition. The Group believes that all its employees may be exposed to the risk of corruption. Nevertheless, as part of the corruption risk mapping exercise, certain functions have been identified as being the most at-risk, including purchasing, sales, customs, logistics and public affairs. 4.11.2.3 Michelin’s whistleblowing system (ethics hotline) 4.11.2.3.1. General presentation Since 2021, a single Group-wide whistleblowing system has been deployed in every Group entity, replacing the regional alert mechanisms that had been in place since 2005. Available in 30 languages, the system may be accessed by Group employees, contractor employees and temporary workers, as well as by customers, suppliers, service providers and other outside stakeholders via a hotline and a secure website hosted by an independent company. The system allows whistleblowers to anonymously and confidentially report any behavior, practice or situation that allegedly violates applicable laws, internal procedures or the Group’s values and principles as set out in the Code of Ethics. As stated in the Code, possible violations may also be reported through such traditional channels as direct or other managers, the Personnel Department or the Regional Ethics Correspondent. All reports are consolidated in the Group’s whistleblowing hotline and presented regularly to the Group Ethics Committee and once a year to the Group Management Committee and the Supervisory Board’s Audit Committee. Based on the reported information, the Regional Ethics Committees concerned decide if the alert is admissible and if it warrants an internal investigation. If the investigation substantiates the alleged violations, the Committees define and deploy action plans with remedial measures and/or disciplinary sanctions up to and including dismissal. Deployment of the ethics hotline has been extensively publicized across the Group to remind employees of its existence and its procedures and to report its usage statistics. Information posters are also on display at Group sites. All employees may request training in how to use the ethics hotline. 289 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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