Sustainability Statement Workers in the value chain (S2) 04 n thoroughly mapping social and environmental risks in the natural rubber value chain, down to the smallest holder, using the RubberWay mobile app. Supply chain stakeholders, including raw rubber processing plants, brokers, large plantations and smallholders, are asked to respond to a questionnaire about their practices in such areas as human rights, the environment, agricultural training and market transparency. The inputted data can then be analyzed and summarized on a web platform to create a map highlighting the areas of potential social and environmental risk. 4.9.4 PROCESSES TO REMEDIATE POTENTIAL NEGATIVE IMPACTS If the Group finds that it may have caused a significant negative impact on workers in the value chain, appropriate remedial actions can be defined or approved by two key governance bodies: the Human Rights Governance body, which approves the Group’s human rights policy, objectives and strategy, and, if the impact occurred in the natural rubber supply chain, the Sustainable Natural Rubber Committee. If the negative impact is confirmed, the remediation response is defined on a case-by-case basis. To improve its ability to detect adverse impacts, the Group has opened an ethics hotline that can be accessed by Group employees, contractor employees, temporary workers and any other value chain worker, as well as by customers, suppliers, service providers and other outside stakeholders via a dedicated telephone number and a secure website hosted by an independent company(1). If, in response to an ethics hotline report, remediation or reparation proves necessary, the victims are contacted, reparation measures are undertaken and prevention mechanisms are strengthened. Compensation may be paid, depending on the situation. Any Group employee, regardless of his or her level of responsibility, who fails to uphold human rights will be disciplined in accordance with applicable laws and procedures. If a contractor, customer, supplier or other business partner is found to have violated human rights or failed to prevent human rights risks, the individuals or, in the case of a company, the managers are contacted to find and initiate remedial solutions. Failure to deploy remedial or corrective measures may result in the decision to terminate the business relationship. In the case of the natural rubber value chain, the GPSNR grievance mechanism may be used if an individual, group or GPSNR member has been adversely impacted by the activities or operations of the GPSNR or its members. The GPSNR website lists the channels available to its members (including Michelin). Lastly, the Natural Rubber Stakeholders Committee can alert the Group to situations concerning workers in the natural rubber value chain. 4.9.5 A WIDE ARRAY OF INITIATIVES IN PLACE TO PREVENT NEGATIVE IMPACTS AND DELIVER POSITIVE IMPACTS Michelin is pursuing a number of initiatives aimed at preventing and/or mitigating human rights risks in the value chain, both on a dayto-day basis and over time. 4.9.5.1 Initiatives to prevent negative impacts from occurring Structurally, the Sustainable Natural Rubber Policy is appended to all the Group’s natural rubber purchasing contracts, while the supplier code of conduct (Michelin Purchasing Principles) is incorporated into the Group’s general terms and conditions and all its contracts. The latter require that suppliers perform CSR assessments and deploy any necessary action plans and authorize Michelin or its mandated service providers to carry out on-site audits. In the event of refusal, Michelin reserves the right to respond as warranted, including by terminating all or part of its business relations with the supplier. Another important prevention/mitigation lever is mapping to identify the sourcing countries and purchasing categories most at risk of CSR shortcomings, with a dedicated mapping exercise for the natural rubber supply chain using the RubberWay application. Third-party assessments of the CSR maturity of leading Tier 1 suppliers (usually desktop reviews by EcoVadis) also play a core role in risk prevention. These reviews cover such human rights issues as forced labor and child labor. For compliance, a predefined score must be earned, both overall and on human rights performance. If supplier answers fall short of compliance, action plans are requested. Supplier performance on forced labor and child labor issues is reviewed in depth every six months and suppliers are queried if any particular risk is flagged. (1) For more on the Michelin ethics hotline, see section G1 – Business Conduct, below. 276 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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