04 Sustainability Statement Business conduct (G1) Impacts, Risks and Opportunities (IROs) Brief description Upstream value chain Downstream value chain Own operations Short-term Medium-term Long-term G1 – BUSINESS CONDUCT Business ethics and corporate culture Fines, litigation and reputational damage due to unethical business practices Potential unethical business practices include corruption, fraud, bribery, environmental violations and exploitive conditions in the supply chain. Risk Introduction Unethical business conduct represents a risk for Michelin, whose employees may be exposed to unethical practices in the course of their business relationships. Failure to comply with applicable regulations could have serious, lasting or irreversible consequences for the Michelin Group’s image and reputation with institutions and/or the general public. This could hamper the Group’s ability to attract talent and capital or expose it to financial risks, such as fines or the costs incurred in compliance, litigation or crisis management. Managers and employees involved in unethical practices may also be exposed to fines and/ or imprisonment. Michelin is formally committed to acting ethically in all its business activities and, in particular, to fighting corruption. It expects every employee to act consistently with integrity, in respect of the internal and external standards that have underpinned its corporate culture for over a century. Compliance with the Group’s fundamental values depends on the commitment of every employee, regardless of job title or function. They are expected to safeguard the values, reputation, image and heritage that the Michelin Group nurtures and enhances over time in order to protect both its employees and its long-term viability. 4.11.1 GOVERNANCE The role of the administrative, management and supervisory bodies See section 4.1.2 Governance of sustainability matters, above, for a presentation of the role of the administrative, management and supervisory bodies related to business conduct, as well as the expertise of these bodies in dealing with business conduct matters. In the Corporate Legal Department, a multi-disciplinary Compliance Support Group (CSG) is tasked, in particular, with preventing and managing the risks of non-compliance with the Group’s Code of Ethics, including in relation to anti-corruption and influence peddling. The CSG takes a holistic, multidisciplinary approach to ethical and compliance risks. Its primary mission is to maintain high-quality protection for the Group and its employees through the creation and deployment of robust compliance programs. The CSG works in close collaboration with its Compliance network and the Group’s other corporate departments (personnel, audit, internal control, communication, sustainable development and impact, purchasing, etc.). The Group’s Compliance network is tasked with instilling the values and principles of the Code of Ethics in the Regions, deploying training initiatives and ensuring proper application of the procedures. Regular meetings are organized with the Regional General Counsels and/or the Regional Compliance Officers to drive the wider deployment of compliance programs and the sharing of best practices. Each Regional Compliance Officer, who is a member of the Regional Ethics Committee, reports once a year to the Group Ethics Operational Committee on the status of the compliance programs, with a summary then presented to the Group Ethics Committee. Upstream Downstream OP OP 287 2024 UNIVERSAL REGISTRATION DOCUMENT_MICHELIN
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