_272 2023 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN 4 NON-FINANCIAL STATEMENT Sustainable Development Report Updated in 2023, the Program is based on a risk map, plotted with the support of an outside provider, and covers: ● competition law procedures and guidelines, some general and others specific to certain issues; ● tracking the business contracts listed in dedicated databases; ● managing sensitive information flows, arising in particular from the Group’s vertical integration in both production and distribution; ● awareness-building initiatives and classroom and e-learning courses for employees in the most exposed jobs, particularly in sales or in positions that have an impact on the Group’s market behavior; ● deployment tracking procedures; ● specific internal control procedures; ● internal audits. The ACP Program is led by the Group Competition Officer and deployed in the operating regions by a network of experts in the Regional Legal Affairs Departments. Each expert is tasked with ensuring the program’s effective deployment in his or her remit across every Group unit, in accordance with the risk ownership principle. The Program contains a “tone at the top” message from the Managers urging employees to ensure compliance, which is shared with participants during the training sessions. As from 2024, deployment of the ACP Program will be reported to the Group Ethics Committee. 4.1.4.1 e) Protecting employee privacy and personal data Michelin pays special attention to protecting the personal data of customers, employees, job applicants, shareholders and suppliers. As part of this commitment, it has deployed a governance system based on a Global Personal Data Protection Committee, a Group Data Protection Officer (DPO), a corporate Privacy team in the Compliance Support Group, and a network of local privacy managers/DPOs, Privacy Operation Partners and Privacy Champions. This system tracks compliance with applicable legislation, including the European Union’s General Data Protection Regulation (EU) 2016/679 (GDPR), China’s Personal Information Protection Law (PIPL)(1), the US Foreign Corrupt Practices Act (CCPA)(2), and Brazil’s General Data Protection Law (LGPD)(3), as well as the Group’s own internal privacy policies. The Group encourages every subsidiary, regardless of location, to apply these same personal data protection principles. Employees are informed of these principles, in accordance with the Group protection of personal data directive. In addition, the Group has issued binding corporate rules concerning the transfer of personal data outside the European Union. Michelin takes special care to properly manage customer and user requests and complaints. In each country concerned, data protection teams are tasked with responding appropriately to each requester in a timely manner. Similarly, in the event of a personal data breach, the Privacy teams are systematically called in, in particular to identify cases where user data has been compromised, and who must be notified with full details so that they can take appropriate measures. Lastly, personal data protection is an integral part of the Group’s internal control process and is periodically audited internally. 4.1.4.1 f) Combating tax evasion Michelin’s tax policies are defined and implemented in line with its operating objectives in responsible and sustainable business development. In this regard, the Group’s primary responsibility is to ensure that it fulfills all of its international, regional and local tax obligations, in both the spirit and the letter of the law. Moreover, Michelin has defined its own fundamental guidelines, in a commitment to securing its positions and ensuring that the Group fairly pays all of the taxes due in its host communities. This is why Michelin systematically interprets tax legislation in compliance with both the law and the legislator’s intent, without taking advantage of any possible loopholes. The Group also recognizes the need and the value of nurturing trust-based relationships with tax authorities. As a result, the Group Vice President of Tax Affairs and members of his network foster, nurture and maintain ongoing, transparent relationships with tax authorities at every level. Whenever possible, the Group seeks to foster such relationships in every host geography. In 2019, for example, the Group signed a partnership agreement with the French tax authorities, under the "relationship of trust" framework set up by the Budget Ministry, whereby we will transparently share any major events likely to have a tax impact. Naturally, the Group’s tax policies strongly condemn all forms of tax evasion and expressly forbid management from taking advantage of tax regimes deemed to be prejudicial or non-transparent. Similarly, Michelin does not engage in any transaction, financial or otherwise, that would have the effect of evading taxes or of optimizing its corporate tax liability without generating any other operational or economic benefit. (1) PIPL: Personal Information Protection Law. (2) CCPA: California Consumer Privacy Act. (3) LGPD: Lei Geral de Proteção de Dados Pessoais.
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