4 _267 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report 4.1.4 Ethics and compliance Michelin is formally committed to respecting ethical standards and fighting corruption. The Group has a dedicated organization in place to address ethical and compliance issues. Organization Chaired by the General Manager, the Group Ethics Committee includes eight other standing members representing the Corporate Customer Experience Department, the Impact and Sustainable Development Department, the Corporate Internal Audit, Risk Management, Internal Control and Quality Department, the Purchasing Operational Department, the Corporate Legal Department (with two representatives, the Group General Counsel and the Chief Compliance Officer), the Corporate Information Systems Security, Safety & Security and Environment Department, and the Corporate Personnel Department. The Ethics Committee meets at least four times a year, with the remit to: ● promote a culture of ethics and compliance throughout the Group and in its relations with third parties; ● define the Group’s ethics and compliance strategy and its effective, consistent deployment in the regional organizations and every Group member company; ● approve the Group’s anti-corruption and other compliance programs, the resulting key corporate procedures and the initiatives required to drive continuous improvement across all these programs. The corporate organization is supported by a local organization structured around Ethics Committees in each Region, chaired by the Regional Presidents and responsible for managing ethical risks in their remit, and by a compliance network of local Compliance Officers. The Compliance network is tasked with instilling the values and principles of the Code of Ethics, deploying training initiatives and ensuring proper application of the procedures. Regular meetings are organized with local Compliance Officers to ensure that the regional organizations are widely and effectively deploying compliance programs and sharing best practices. Since 2021, a Chief Compliance Officer (CCO) has been appointed to prevent and manage risks of non-compliance in such areas as corruption and influence peddling, competition rules, privacy and personal data, the environment, ethics, harassment and fraud. As part of the Corporate Legal Department, the CCO heads a multi-disciplinary Compliance Support Group (CSG) made up of experts in various ethics and compliance issues and a number of operations compliance officers. It is in charge of (i) managing the digital applications in place across the Group to address ethical issues (whistleblowing system, third party due diligence); (ii) leading certain dedicated projects (corruption and fraud risk mapping exercises, third-party corruption due diligence); and (iii) coordinating ethics investigations, internal legal, ethics and compliance audits, and the training and communication plan concerning issues within the Compliance Support Group’s remit.
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