4 _271 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report CASES BY ISSUE CASES BY REGION 4.1.4.1 b) Taking a firm stand against corruption Attesting to the Group’s commitment to deploying a policy of zero tolerance for any form of corruption, a clear, practical Anti-Corruption Code of Practice was issued to all employees and outside partners in 2015 and updated in 2020. 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. The Code of Ethics, first issued in 2021 and now being updated, reaffirms the principles that should govern the decisions of any employee confronted with a situation that could be construed as corruption. Since 2021, Michelin has continued to improve its anticorruption compliance program by: ● reiterating the commitment of senior management in the 2021 Code of Ethics; ● updating the dedicated Group-level corruption risk map; ● reinforcing the third-party due diligence process (including specific anti-corruption due diligence prior to any merger or acquisition) and addressing ESG aspects in due diligence audits; ● continuing and expanding the training curriculum with a mandatory online anti-corruption course and dedicated classroom courses for people in the most exposed positions; ● regularly updating the internal ethics and compliance procedures, covering in particular details of the anticorruption compliance program, gifts and invitations, and conflicts of interest; ● strengthening existing internal controls; ● conducting internal audits. As part of the anti-corruption compliance program, the Michelin Group has also introduced a key performance indicator tracking the percentage of employees who have undergone anticorruption training. Deployed since fourth-quarter 2021, the elearning program, which reviews the fundamental principles of the fight against corruption, is designed for all managers and employees worldwide. The tracking target is ≥ 98%. As of December 31, 2023, more than 39,000 Michelin Group employees had completed the course, representing 98% of the target, a full six points higher than in 2022. 4.1.4.1 c) Taking a firm stand against fraud Consistent with its ethical values, Michelin condemns and assertively combats any form of fraud throughout the Group. This commitment is enshrined in the Code of Ethics and, since 2023, in a new version of the internal fraud risk management procedure. This procedure describes the mechanisms for preventing, detecting and dealing with suspected fraud and specifies the compulsory process for tracking the action plans undertaken in response to substantiated fraud. It also describes the governance system in place to manage fraud risk. The procedure was deployed Group-wide in 2023. 4.1.4.1 d) Competition law Michelin has long adhered to the highest standards of competition law compliance. Since 2004, a dedicated antitrust compliance program (ACP) has been in place, using classroom training courses to help foster a strong culture of competition law compliance across the Group. 13% 5% 28% 3% 6% 23% 9% 13% Protection of goods Employee relations Confidentiality Non-compliance with internal policies Harassment Discrimination Environment and safety Business ethics Asia Europe 15% 11% Africa, India, Middle East 38% North America 17% South America 19%
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