Sustainability Statement Business conduct (G1) 04 4.11.2.4 Ethics training The Group offers a number of business conduct training courses intended either for all employees or for people in the most at-risk functions. They cover a range of subjects and issues, including the Code of Ethics, the ethics hotline, harassment, antitrust, anticorruption, personal data protection and conflicts of interest. The courses are mandatory and must be attended when the employee takes up his or her new position and every two years thereafter. In particular, given that all Group managers and employees worldwide may be exposed to corruption risks, since the final quarter of 2021, everyone qualified as eligible, wherever they work around the world, is expected to attend, every two years, an e-learning program reviewing the fundamental principles of the fight against corruption. The program enables participants to (i) understand the concepts of corruption and influence peddling; (ii) onboard the main principles of France’s Sapin II Act and the related compliance system; (iii) identify situations at risk of corruption and influence peddling and recognize the consequences of violations; (iv) avoid situations likely to create a conflict of interest; and (v) use the whistleblowing channels to report possible infringements. 4.11.3 INITIATIVES SUPPORTING BUSINESS CONDUCT POLICIES AND THE CORPORATE CULTURE In 2024, as every year, initiatives were undertaken to ensure compliance with the Code of Ethics, the Anti-Corruption Code of Conduct and the Anti-Corruption Compliance Program. The Group Ethics Committee is currently updating the Group’s corruption risk map, at the pace of three Regions per year in 2024, 2025 and 2026. At the same time, the third-party due diligence process introduced in 2021 was strengthened in 2024, including specific anti-corruption due diligence prior to any merger or acquisition and the inclusion of ESG issues in due diligence audits. During the year, assessment criteria were reviewed, to realign the criteria for identifying at-risk third parties, lower the “at-risk country” threshold, deploy third-party assessments of suppliers in the Northern Europe Region in compliance with the German Duty of Care Act (LkSG) and introduce an upstream assessment procedure for new suppliers. Internal ethics and compliance procedures are regularly updated. In 2024, a review of the Code of Ethics was initiated and the AntiCorruption Compliance Program was updated. In 2025, the Group’s Gifts and Entertainment Directive and Anti-Corruption Code of Conduct are scheduled for revision, as is the Third-Party Assessment Procedure to incorporate the new criteria identified in 2024. The Group is continuing to develop and deploy mandatory online and in-person training courses for the most at-risk functions, including a mandatory anti-corruption e-learning course for the most exposed employees. 4.11.4 PREVENTION AND DETECTION OF CORRUPTION AND BRIBERY The Anti-Corruption Compliance Program is designed to prevent and detect allegations and incidents of corruption, influence peddling and bribery. The Code of Ethics, the Anti-Corruption Code of Conduct and mandatory training courses all contain a presentation of the corruption and bribery detection procedures(1). As part of the Anti-Corruption Compliance Program, Michelin has also introduced a key performance indicator tracking the percentage of employees who have undergone anti-corruption training, which is mandatory for all employees in the more at-risk functions (see above). (1) See above for a description of these guidelines. 292 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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