Michelin CGDE : Master Policy on Human rights

MICHELIN

MASTER POLICY ON HUMAN RIGHTS

MICHELIN MASTER HUMAN RIGHTS POLICY

SUMMARY

I. GENERAL POINTS

INTRODUCTION

SCOPE OF THE POLICY

HUMAN RIGHTS POLICY

AND LOCAL LAW

GOVERNANCE

IMPLEMENTATION OF THE DUTY

OF VIGILANCE

ACQUISITIONS AND CREATION

OF JOINT VENTURES

SUPPLIERS

REPORTING, REMEDIATION

AND SANCTION MECHANISM

II. PRINCIPLES BY SUBJECT

DISCRIMINATION

HARASSMENT

HEALTH & SAFETY

DECENT WAGE AND SOCIAL PROTECTION

FREEDOM OF ASSOCIATION

AND COLLECTIVE BARGAINING

PRIVACY AND PERSONAL DATA

CHILD LABOUR

FORCED LABOUR

IMPACT ON LOCAL COMMUNITIES

03 - 06

03

04

04

04

05

05

06

07

08 - 13

08

09

09

10

10

11

11

12

13

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MICHELIN MASTER HUMAN RIGHTS POLICY

I.GENERAL POINTS

INTRODUCTION

Since its origins in the 19th century, the Michelin Group has been especially concerned with the well-being of its employees, and respect for people is one of its founding values. Today, the company is aware more than ever of its responsibility towards its various stakeholders. The "All Sustainable" strategy that governs all its activities advocates balance between People, Planet and Profit, and respect for all the stakeholders with which it interacts: employees, business partners, suppliers, local communities, etc.

This policy is also part of the duty of care that Michelin recognizes it has towards all its stakeholders. It specifies the Group's expectations concerning this duty of care with regards to human rights.

The principles conveyed by this policy for each subject are guided directly by our ethical values and international law, and in particular by the fundamental ILO conventions and the UN guiding principles on business and human rights and the Universal Declaration of Human Rights. These are also the results of many working sessions with the UN Global Compact and other bodies specializing in these subjects.

While several of Michelin's founding documents already set out the company's undertakings on some subjects(1) coming under human rights, the Group wished to present a clear and accessible summary of the main actions required in this matter in a single document. This policy is specified and completed in the various, more detailed documents to which reference is made in some chapters.

(1) These include: Diversity and Inclusion Policy, Health and Safety Policy, Anti-Harassment Policy, Purchasing Principles, Code of Ethics, Employee Relations Policy.

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I. GENERAL POINTS

MICHELIN MASTER HUMAN RIGHTS POLICY

SCOPE OF THE POLICY

This policy applies to all activities by Michelin, its subsidiaries and joint ventures in which the Group is the majority holder.

It is also promoted in the companies in which Michelin holds a minority or 50/50 share.

The Group's suppliers are asked to comply with Michelin's Purchasing Principles, which are in line with this policy.

All our stakeholders and in particular our business partners are made aware of this Human Rights policy and the main documents that complete it (in particular the Purchasing Principles). Michelin uses its power of influence to ensure that the policy is respected by its partners, and in particular by its suppliers.

HUMAN RIGHTS POLICY AND LOCAL LAW

The Group's entities implement this policy, including in countries where the local regulations are not prescriptive on these subjects.

In the event of a difference between the national legislation and this policy, the standard most protective of human rights shall apply.

If, for a given subject, this policy proves to be contradictory to local law, the latter must be applied, and solutions must be sought to allow compliance with the spirit of this policy's principles.

When this policy goes against local customs without being contrary to local law, it must nevertheless be applied by management in good faith.

GOVERNANCE

The Group's human rights governance(2), as well as that for the health and safety of people on subjects concerning them, are responsible for defining, applying, deploying and updating this policy. They decide on the actions for progress and improvement, in accordance with the results seen and new knowledge in this topic.

In the Group's various geographical regions, the Regional Director is the guarantor for implementing it in all the companies and entities in his/her scope. To do this, he/she may appoint one or more operational managers (HR, Purchasing, Industry, etc.) and rely on the regional ethics committee to handle complaints on ethical lines(2). These managers are trained in human rights.

1. The Group's Human Rights governance is chaired by the Director of Personnel and includes three members of the Executive Committee.
2. Especially for complaints relating to harassment.

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I. GENERAL POINTS

MICHELIN MASTER HUMAN RIGHTS POLICY

IMPLEMENTATION OF THE DUTY OF VIGILANCE

Given the extremely vast field concerned by the expectations of the human rights policy, the following is requested, at Group level and at geographical region level, across all the fields of this policy, distinguishing Michelin Group activities from those of suppliers:

1. Perform risk assessments in order to identify the main risks on human rights(4). These maps are regularly updated.
2. For the topics identified as a priority, analyse the variance between the actual situation and the policy expectations.
3. When differences are noted between the local situation and the requirements of this policy, draw up and implement action plans.

1. Define monitoring and progress indicators, the results of which are presented regularly to the human rights governance(5).
2. If, for a given country, it is considered that the variances cannot be overcome satisfactorily due to a specific context, the human rights governance(6) must be informed in order to take the appropriate decisions.

This implementation of the duty of care on human rights is an ongoing process of progress that will continue over time.

ACQUISITIONS AND CREATION OF JOINT VENTURES

A human rights evaluation (due diligence) is performed during the acquisition of a new company or the creation of a joint venture. The information from this analysis is taken into consideration during the decision-making phases of the acquisition or joint-venture creation project.

Clauses relating to human rights must be integrated into all our acquisition and joint-venture contracts and Michelin must ensure their proper application.

Furthermore, if this proves necessary, a human rights action plan is defined and implemented to reach the Group's standards within a maximum of 5 years.

With regards to the companies in which Michelin holds a minority share, Michelin's company representatives are trained in human rights and bring the principles of this policy to board meetings.

1. The main criteria for risk analysis are: the severity of the impact on people and the probability of occurrence. External organizations, such as VeriskMaplecroft, can help define the level of risk.
2. And to the Ethics Committee when in relation to harassment.
3. And the Ethics Committee when in relation to harassment.

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