Michelin

Governance roles

Reference: pages 169-170.

The Supervisory Board has 11 members, all non-executive, with an Audit Committee and a Corporate Social Responsibility (CSR) Committee, both chaired by independent members. At December 31, 2025: 5 of 11 members are women (45.5%), 3 represent other nationalities (27.3%), and 8 are independent (72.7%) - unchanged from 2024.

Details of CGEM's administrative bodies, their composition, responsibilities and the expertise/training of members are incorporated by reference to the Corporate Governance Report (Chapter 2, sections 2.1 and 2.2).

Information provided to the Supervisory Board's CSR Committee

Reference: page 170.

The CSR Committee "plays an oversight role on sustainability issues" and, every four months, "reviews the Group's sustainability strategy, objectives, policies and commitments," coordinating with the Audit Committee on the double materiality assessment (DMA).

In 2025 the Committee addressed: CSR regulations and competitiveness, the climate plan, corporate citizenship strategy, water strategy, AI ethics, circular economy and social dialogue. Sustainability governance runs through four bodies: the Group Executive Committee, the Group Management Committee, the Environmental and Social Governance bodies, and Thematic/Operational Committees.

ESG criteria in Manager compensation

Reference: page 172.

For 2025, as in 2024, Managers' variable compensation carried ESG criteria: 20% of annual variable compensation depends on ESG targets (accidentology rate, gender balance, and Scope 1&2 CO2e emissions), and 40% of deferred (performance-share) compensation depends on ESG targets (Rolling Resistance/Renewable and Recycled Materials Rate at 20%, and employee engagement rate at 20%). The accidentology and CO2e targets also apply to all employees eligible for the Group Bonus, and both performance-share criteria apply to every employee eligible for the plan.

Statement on due diligence

Reference: pages 172-173.

In 2025, as every year since 2017, Michelin prepared a Duty of Care Plan under French Act No. 2017-399, identifying risks to the Group and its value chain and describing measures to prevent and mitigate adverse impacts on the environment, health and safety, and human rights. It incorporates a double materiality assessment and is built around the Code of Ethics, Purchasing Principles, Supplier Relations Code of Conduct, and Health, Environment, Diversity & Inclusion and Human Rights policies.

The report maps the five core due-diligence elements (governance embedding, stakeholder engagement, impact identification, action, and tracking effectiveness) to specific sections of both the Sustainability Statement and the Duty of Care Plan.

Risk management and internal controls over sustainability reporting

Reference: pages 173-174.

Non-financial reporting has been part of the Group's risk management system since 2022. Milestones: a Sustainable Finance Governance body created in 2022 (chaired by the General Manager); two internal audits (2022, 2023) assessing reporting reliability; addition in 2023 of "inaccurate or unfair reporting of non-financial data" to the Group's risk database; and a 2024 internal control system for downstream reporting phases.

Internal control runs through self-assessments (first line of defense) and testing (second line); non-compliance triggers corrective action plans within three months, with effectiveness measured the following year. Results go to the Audit Committee each April. The 2024 DMA's material matters were cross-checked against the Group risk map for alignment.

Strategy, business model and value chain

Reference: pages 174-176.

Michelin's "Michelin in Motion" strategic plan (launched 2021) sets a 2030 roadmap and 2050 vision. In 2025 the Group defined four "hallmarks" with stakeholders: energy efficiency, materials management, social innovation, and excellence in employee health and safety.

The value chain diagram maps material topics (E1-E5, S1, S2, S4, G1) across upstream (raw materials, other purchases/suppliers), logistics, Michelin operations, downstream B2B & B2C distribution, usage and end of life. Natural rubber, synthetic rubber and reinforcing materials are named upstream inputs. Own operations cover manufacturing; downstream covers transport/storage of finished products, distribution, usage and end-of-life treatment.

Stakeholder dialogue

Reference: pages 177-180.

Michelin maps eight stakeholder groups: the Corporate Stakeholders Committee (civil-society think tank since 2016; in 2025 held a physical meeting on biodiversity and mental health, plus a sustainable-product-performance webinar), civil society/NGOs (FIDH, Oxfam, Transport et Environnement, WWF), customers, employees and representatives (European Works Council met October 21-22, 2025; Global Works Council October 23), shareholders/investors, suppliers, public authorities/trade organizations, academia, and local communities.

With employee representatives specifically, "Michelin consulted the European Works Council on the subject [of sustainability reporting] on October 21, 2025."

Material impacts, risks and opportunities

Reference: pages 182-186, with topic detail cross-referenced at pages 237 (E4), 262 (S1), 273 (S2) and 280 (S4).

As in 2024, the 2025 double materiality matrix comprises 26 material IROs. "In 2025, no major event or material change concerning the Group's scope of consolidation or business model... was identified as being likely to modify the sustainability matters... The Sustainable Finance Governance body therefore decided to roll over the double materiality assessment to the 2025 fiscal year." ESRS S3 (affected communities) fell below the materiality threshold; DEI and social-dialogue IROs also fell short but are still discussed qualitatively. The materiality matrix plots each IRO by impact and financial materiality, e.g. E1 climate mitigation (Scopes 1&2) and S2 human rights in the value chain rank highest on impact materiality.

Double materiality assessment methodology

Reference: pages 181-183.

The 2025 matrix was rolled over unchanged from the 2024 assessment (approved and threshold-set by the Group Executive Committee in April 2024), performed with third-party support across four steps: definition of ESG topics/analysis grids, identification of IROs, consolidation/tiering, and final validation by the Group Executive Committee (CEG) and Group Management Committee (CDG). Financial materiality is scored 1-5 (under EUR50 million to over EUR900 million); impact materiality assesses severity/extent/irremediability for negative impacts and scale/scope for positive ones, with severity taking precedence over likelihood for potential human-rights impacts. IROs are scenario-built "gross" (before mitigation) over short/medium/long-term horizons.

ESRS content index

Reference: pages 189, 306-311 (Appendix D - Table of Disclosure Requirements).

Appendix D lists, for every ESRS 2 and topical disclosure requirement, the corresponding Universal Registration Document (URD) section, or a literal "Not material" / "Not disclosed in 2025" marker where no content is given. Items explicitly marked "Not material" in Appendix D: S1-8, S1-9, S1-12, S1-15, S1-16, G1-2, G1-5, G1-6. Items explicitly marked "Not disclosed in 2025" (distinct from "not material"): E2-6, E3-5, E4-6, S1-7, S1-11. Appendix B separately cross-references SFDR, Pillar 3, Benchmark Regulation and EU Climate Law datapoints to the same URD sections.

Transition plan for climate change mitigation

Reference: pages 192-197.

Michelin's transition plan targets net-zero emissions by 2050 in Scopes 1, 2 and required Scope 3 (excluding use-phase), with interim 2030 targets versus the 2019 baseline: -47.2% for Scopes 1 and 2, and -27.5% for required Scope 3 (purchased raw materials, logistics, upstream purchased energy). SBTi approved the targets in 2024 as consistent with a 1.5C pathway. The plan is overseen by the Managers with the Group Executive Committee and Environmental Governance body; annual plans go to the Supervisory Board's CSR Committee. A portion of variable pay for Managers and all employees is tied to Scope 1&2 targets. The Group is not excluded from EU Paris-aligned benchmarks, and had not, as of 2025, allocated significant monetary amounts specifically against the transition plan beyond the CapEx detailed under E1-3/E1-9.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 (page 198) and the E1 physical-risk review (pages 213-214). This disclosure requirement did not exist under the 2023 ESRS the FY2025 report was prepared against (the statement confirms it applies "the final French language version of the European Sustainability Reporting Standards (ESRS), issued in December 2023").

Michelin assesses climate-related risks via four internally-built climate/societal scenarios (qualitative narrative plus Kaya-identity metrics) mapped against IPCC warming pathways, reassessed in 2021 and refreshed for consistency with IPBES biodiversity scenarios in 2025. For physical risk exposure specifically, in 2024-2025 the Group used two disaggregated IPCC scenarios: SSP2-4.5 (median warming of 2.7C by 2100) and SSP5-8.5 (4.4C), covering several thousand Michelin, supplier, customer and transport-infrastructure sites for current conditions and 2030/2050 horizons. Hazards assessed: dry/humid heat, water stress/drought, floods, strong winds and landslides.

Resilience in relation to climate change

Back-filled from section 4.2.6 "Resilience of the strategy" (pages 197-198). This disclosure requirement did not exist under the 2023 ESRS the FY2025 report was prepared against.

In 2021 the Group Executive Committee reassessed strategic resilience against the four climate scenarios and concluded that "strategic fundamentals are validated in every scenario," while flagging knock-on risks (e.g. biodiversity degradation harming rubber-tree farming) and innovation priorities (reduced materials footprint, end-of-life tire solutions, heat-adapted products). Various social, environmental, legislative and resource-depletion "shocks" are simulated to stress-test the strategy and identify blind spots. On physical-risk resilience specifically, the Group has analyzed exposure for thousands of sites but states that, from 2026, adaptation measures and a more precise cost estimate will follow site-level vulnerability assessments - i.e. the resilience work is still being operationalized rather than fully quantified.

Climate change mitigation policies

Reference: page 199.

The Group's Environmental Policy (public reference document issued 2021, updated in parts in 2025) governs climate mitigation through its "Production and R&D sites" chapter, which sets procedures for reducing Scope 1&2 CO2e emissions. The decarbonization plan covers the 2030/2050 SBTi-approved targets across the consolidated financial reporting scope; for 2025, excluded Scope 1&2 emissions were an estimated 2.7% of the Group total and excluded required Scope 3 an estimated 2.2%, so the inventory covers at least 95% of total Group emissions, in line with the SBTi target scope.

Actions and resources embedded in the business model

Reference: pages 199-203, 213-215 (adaptation actions).

Mitigation levers follow the Avoid-Reduce-Reuse-Recycle-Renew hierarchy: energy sufficiency (fixed-consumption control at 30 priority sites) and energy transition (fuel substitution, renewable electricity purchases - 68% of 2025 electricity consumption, via >3,084,000 MWh of EAC-backed contracts). CapEx for CO2e/energy reduction was EUR86 million in 2025 (EUR107 million in 2024), with over EUR300 million budgeted over the next five years; coal is being phased out by 2030 at four remaining sites (Pirot, Bassens, Louisville, Shenyang). On adaptation, a vulnerability-assessment methodology and tool were developed and piloted in 2025, with training and site prioritization planned from 2026, and natural-rubber-sourcing diversification already underway.

Decarbonization targets

Reference: pages 192-193, 207.

SBTi-approved targets versus the 2019 baseline: Scopes 1&2 -47.2% by 2030 / -90% by 2050; required Scope 3 -27.5% by 2030 / -90% by 2050. Over 2019-2025 the Group achieved a 47.7% cut in Scopes 1&2 CO2e, meeting the 2030 target five years early. A separate target calls for a 10% improvement in rolling resistance by 2030 (vs. 2020); 5.8% had been achieved by end-2025. Targets are validated by the Science Based Targets initiative (2024) and consistent with the SBTi Corporate Net Zero Standard.

Energy consumption and mix

Reference: pages 203-205.

Total energy consumption from own operations fell to 9,750,121 MWh in 2025 (10,409,164 MWh in 2024), a 6.3% year-on-year decline. Mix: fossil sources 63% (6,172,619 MWh, down from 66%), nuclear 4% (396,264 MWh), renewable 33% (3,181,237 MWh, up from 29%). Energy intensity was 375 MWh/EURm (383 in 2024). Renewable electricity accounted for more than 97% of renewable energy use; 58% of renewable electricity purchases were bundled EACs and 42% unbundled. Against the 2019-2030 target of a 24% improvement in plant energy efficiency, the Group had achieved only 4% by 2025, prompting an acceleration program.

Gross Scope 1, 2, 3 and total GHG emissions

Reference: pages 205-208.

Gross Scope 1: 826,304 tCO2e (2025), down 13.6% from 956,909 t (2024); baseline 2019: 1,725,839 t. Gross market-based Scope 2: 860,289 t (2024: 1,069,582 t). Market-based Scopes 1+2: 1,686,593 t, a 47.7% cumulative cut versus the 2019 baseline of 3,439,038 t, beating the 2030 SBTi target (-47.2%) five years early. Required Scope 3 (market-based): 13,782,821 t (2024: 14,750,899 t). Scope 3 in-use (not SBTi-scoped but tracked): 125 million tCO2e in 2025 (131 million in 2024), about 90% of Michelin's carbon footprint. Market-based GHG intensity: 530 tCO2e/EURm (542 in 2024).

GHG removals and carbon credits

Reference: page 211.

"The Group's ambitions are compatible with the net-zero emissions target for 2050, which is being pursued without using any carbon credits to offset CO2e emissions from its direct or indirect activities, in accordance with SBTi standards." Carbon credits generated by projects undertaken by the Group's investee funds are accordingly not set off against the Group's own carbon footprint. This is a direct, reasoned nil-return on carbon-credit usage rather than an omission.

Internal carbon pricing

Reference: pages 211-212.

Since 2016 Michelin has applied a standard internal (shadow) carbon price to capital projects materially affecting Scope 1&2 emissions, to steer CapEx toward low-carbon solutions. The price has risen from EUR50/tonne in 2016, to EUR100/tonne in 2021, to EUR200/tonne in 2023 (unchanged in 2025), set by the Managers on proposal of the Environmental Governance body, based on EU allowance-price trends, ROI sensitivity analysis and an external CDP-derived benchmark. It applies to entities in the legacy tire-business scope (97% of Group Scope 1&2 emissions in 2025) and is also used by Scope 3 logistics entities to assess carbon-free alternatives.

Anticipated financial effects

Reference: pages 187, 201, 215.

Financial resources allocated to E1 climate change: EUR237 million in 2025 (EUR226 million in 2024), with over EUR900 million budgeted for the next five years (vs. over EUR1,000 million announced in 2024), split between mitigation in Scopes 1&2 (EUR86 million 2025 / >EUR300 million budgeted) and Scope 3 (EUR151 million 2025 / >EUR600 million budgeted). For physical-risk adaptation, the Group states it is still building the evidence base: "The Group is examining the possible financial effects and, from 2026 onwards, will have a more precise estimate of the cost of adaptation measures, compared to the rough estimate determined on the basis of initial studies carried out on pilot sites" - an explicit statement that quantification is not yet mature, not a gap the company conceals.

Policies related to pollution

Reference: page 218.

Pollution risks are identified and assessed under the Group Environmental Policy, with the riskiest substances addressed by a dedicated Chemical Risk Management Policy that "seeks to replace them with substitutes wherever technically feasible," backed by use restrictions and an HSE approval process for new raw materials. The Policy commits that, "by 2050, no organic solvents are used in the production of its tires." Since 2022, reducing tire and road wear particles (TRWP) has been part of the Environmental Policy's eco-design section, managed through a dedicated program.

Actions and resources related to pollution

Reference: pages 218-227.

Michelin's TRWP program (strengthened 2023) develops abrasion-reducing tire designs and contributed to two 2025 scientific papers (with the Tire Industry Project) synthesizing over 850 publications. SAMPLE, an in-house particle-capture system, found 90% of fine particles behind a tire on open roads are road minerals and brake dust, not tire wear. Michelin is part of a USTMA-led consortium analyzing 6PPD replacement substances (five candidates shortlisted from 60 in 2024; results due mid-2026). For VOCs, air pollution and water pollution, see E2-4 below; for chemical risk, a dedicated Chemical Risk Management Policy governs substitution of the riskiest substances in formulations.

Targets related to pollution

Reference: pages 220-221, 227.

On TRWP, Michelin reports an Abrasion Efficiency Index (AEI) of 108.4 in 2025 against a 2020 baseline of 100, and cites a 2025 ADAC study in which Michelin tires emitted 27% fewer wear particles than the average of tested competitors (160 models tested). No single numeric 2030 TRWP reduction target is stated; progress is instead tracked via AEI. On water pollution, no targets are yet set because the underlying measurement plan "does not yet provide sufficiently exhaustive and robust data to publish reliable water pollution metrics," with reliable annual figures expected within 2-3 years.

Air and water pollution metrics

Reference: pages 225-227.

Air pollution (E2-4-28a1), 2025 vs 2024: NMVOCs 3,498 t (2024: 3,825 t); NOx 309 t (693 t), down 55%, split between non-recurring 2024 items and a 30-60% cut at the Group's three highest-emitting sites from the coal phase-out; SOx 601 t (610 t), masking a generator-driven spike at one site against a ~50% underlying cut at the top emitters. For water pollution, a 2024-2025 materiality assessment under E-PRTR Annex II identified seven material substances (nitrogen, phosphorus, COD, zinc, copper, lead, nickel) now measured by independent laboratories, but "the measurement plan... does not yet provide sufficiently exhaustive and robust data to publish reliable water pollution metrics for 2025." The Group also states it does not publish the ESRS E2-4 paragraph 28(b) "microplastics generated" metric, reporting TRWP instead via the AEI/potential-mass-to-wear metrics described under E2-3.

Substances of concern and very high concern

Reference: pages 227-228.

Michelin discloses the procured amount: total SVHCs procured fell to 1,877 t in 2025 (2,047 t in 2024), an 8% decline tied to lower overall raw-materials purchases, using a 0.1% SVHC-content threshold per CLP/REACH. On the outflow side the Group gives a direct nil return for the product limb: "Tires and tracks manufactured by Michelin contain no SVHCs in excess of 0.1%," because SVHCs used are consumed during manufacturing. For substances of concern (SOC) other than SVHCs, an internal 2025 feasibility study concluded identification and quantification was "neither feasible nor proportionate" given over 4,000 candidate SOCs and up to 200 ingredients per tire formulation; the Group states plainly it "is not publishing the E2-5-34 'substances of concern (SOC)' metric for 2025," limiting its quantified reporting to SVHCs.

Policies related to water and marine resources

Reference: pages 230-231.

The Group's Environmental Policy affirms a "2050 water objective... to not have any impact on water availability in local communities," covering both the sustainable-purchasing (upstream) and own-operations life-cycle stages. Own-operations performance is tracked via the SMEP Environmental and Risk Prevention Management System, including a water-withdrawal indicator, and the Policy sets a 2030 target of a 33% reduction in water withdrawals versus 2019, weighted by each site's water-stress coefficient. New sites are prohibited from withdrawing water from non-renewable underground sources.

Actions and resources related to water and marine resources

Reference: pages 231-233.

The Water Program (multi-disciplinary expert team) applies the Avoid-Reduce-Reuse-Recycle-Renew hierarchy: reducing/eliminating leaks, reducing steam consumption and evaporation, closing open loops, water-saving systems, and recycling/reuse. In the upstream value chain, the Sustainable Purchasing Policy and the Sustainable Natural Rubber Policy address water contamination prevention, wastewater treatment at the first rubber-processing stage, and maximizing water recycling; the Group can reduce sourced volumes from or curtail relations with non-compliant suppliers. The 2024 Physical Climate Risks Adaptation Policy also covers water-stress risk.

Targets related to water and marine resources

Reference: pages 233-234.

The Group's 2030 target is to cut water withdrawals, weighted by each site's water-stress coefficient, by 33% versus 2019 (metric: water stress x cu.m. per tonne of product), aligned with the 2050 "zero impact on water availability" commitment. No target has yet been set for the upstream value chain: "Water consumption targets have not yet been set for the upstream value chain. The Group must first review the findings of the assessments of the suppliers of raw materials other than natural rubber and the data in the RubberWay application."

Water consumption metric

Reference: pages 234-235.

Total water consumption: 8,324,642 cu.m in 2025 (9,504,159 cu.m in 2024). Water withdrawn: 19,675,879 cu.m (22,468,460 cu.m), down about 12% year on year. Consumption in high water-stress areas: 887,009 cu.m (964,822 cu.m), down ~8%. Water intensity: 320 cu.m/EURm (350 cu.m/EURm). The tire-production Stress x cu.m./tonne ratio fell 6.9%, one-third from lower production volumes and two-thirds from efficiency projects. By end-2025, 39% of sites had discharge meters installed, covering more than half of measured discharges; un-metered sites estimate using Group guidelines.

Addressing biodiversity in the transition plan and business model

Reference: page 237.

Michelin has been engaged with the Act4nature International initiative since 2018, "in a commitment to easing the pressure on biodiversity from its operations across the value chain by setting 2030 targets for research and development, natural rubber and other raw material sourcing, and its production and research sites." The Group's biodiversity strategy, policies, roadmaps, targets and metrics are defined and managed by the Biodiversity Sector Committee within the Environmental Governance body. In 2025 the climate/societal scenarios used for strategic resilience (section 4.2.6) were checked for consistency with IPBES biodiversity scenarios, and natural-rubber supply risk from climate pressure on biodiversity is addressed through the E1 adaptation action plan.

Core biodiversity and ecosystem policies

Reference: page 241.

Biodiversity is a key component of the Sustainable Natural Rubber Policy (issued 2015, updated 2021), covering the Group's own operations, joint ventures and upstream supply chain, informed by the 2015-founded Natural Rubber Stakeholders Committee (NGOs and academics; latest meeting early 2025 at the Royal Lestari Utama plantation, Indonesia). The Sustainable Purchasing Policy also addresses biodiversity in sourcing. Since 2013, Michelin sites have inventoried nearby protected areas (updated every five years, latest 2023); in 2025 the Group additionally mapped sensitive host ecological zones using Globio, ENCORE, the IUCN Red List and Key Biodiversity Areas (KBA) tools.

Biodiversity and ecosystem initiatives

Reference: page 243.

Direct-operations actions include the Group's two owned rubber plantations (Bahia, Brazil and Royal Lestari Utama, Indonesia), where ISO 14001 certification and environmental risk assessments incorporate biodiversity criteria (presence of protected areas; IUCN Red List species). In the supply chain, actions combat deforestation and promote more sustainable farming practices; in 2025 Michelin undertook to preserve and restore a further 15,000 hectares of plantations over 20 years, and the RLU site's first Environmental and Social Advisory Committee met in June 2025, covering indigenous-community engagement and human-elephant conflict management.

Biodiversity and ecosystem targets

Reference: page 245.

Two Act4Nature International commitments, renewed in 2024: (1) deforestation-free natural rubber - 2024: 98%, 2025: 98%, 2030 target: 100% (own operations and natural rubber suppliers across Thailand, Sri Lanka, Indonesia, Malaysia, Vietnam, Cote d'Ivoire, Ghana, Nigeria, Guinea Conakry and Brazil); (2) pesticide-use reduction per hectare versus the 2019 baseline (1.59 kg active ingredient/ha) - 2024: -52%, 2025: -69%, 2030 target: -70% (Brazil, Indonesia, Cote d'Ivoire, Ghana, Nigeria plantations). Targets were approved by the Act4Nature International Steering Committee after cross-review for SMART compliance.

Impact metrics related to biodiversity and ecosystems change

Reference: pages 245-246.

Sites in or near biodiversity-sensitive areas: Plantacoes Michelin da Bahia, Brazil - no land cover deforested in five years; ~400 ha of fallowed rubber cropland converted to permanent protected areas; 20 ha reforested. PT Royal Lestari Utama, Indonesia (2 sites, 88,645 ha total, >15,000 ha dedicated to biodiversity) - no land deforested by RLU in five years (rubber was planted on land deforested before Michelin's 2015 involvement); 1,100 additional hectares added to conservation/restoration since 2022. Nearby sensitive areas named include the Atlantic Forest/Michelin Ecological Reserve (Brazil) and Bukit Tigapuluh National Park and Kutai National Park (Indonesia).

Resource use and circular economy policies

Reference: pages 249-250.

The Environmental Policy's "Avoid+4R" process (Avoid, Reduce, Reuse, Recycle, Renew) frames all circular-economy action. The Eco-design Policy, based on ISO 14006:2020 and NF X30-264:2013 and life-cycle assessment, has applied since end-2022 across all Group companies marketing pneumatic tires, solid tires, tracks and ground-contact products; over 90% of R&D employees were trained in recycled/renewable materials, LCA and eco-design by end-2025. The Recycled and Renewable Materials commitment and the Sustainable Purchasing/Sustainable Natural Rubber Policies (for upstream sourcing) complete the framework, alongside an Environmental Policy section on end-of-life tire management currently being revised.

Circularity initiatives and resources

Reference: pages 250-253.

The Group invested EUR34 million in resource-circularity projects in 2025 (EUR12 million in 2024), with over EUR250 million budgeted over the next five years. Named initiatives: retreading/regrooving (210+ kt of truck-tire casings reused in 2025, ~7% of total materials used); the BioButterfly project (bio-sourced butadiene, industrial pilot at Bassens); the Empreinte project (75% renewable/recycled-content tire demonstrator, third-party certified); BlackCycle (completed, end-of-life tire feedstock recycling); WhiteCycle (EUR9.6 million, 16 partners, targeting 2 million tonnes/year of recycled textile fiber by 2030); the Enviro/Antin/Michelin Infiniteria joint venture (first plant in Sweden, 2026, 35 kt/year capacity); and ResiCare (EUR60 million committed in 2025 for a bio-sourced 5-HMF molecule). A first mining-tire recycling plant (Michelin Specialty Materials Recovery) was inaugurated in Antofagasta, Chile in 2025.

Resource use and circular economy targets

Reference: page 253.

Michelin targets 100% renewable or recycled materials in tires by 2050, with a 40% milestone by 2030, tracked via the Renewable or Recycled Materials Ratio (RRMR): 28% (2020 baseline) -> 31% (2024) -> 32% (2025). A second target commits that all new tire radial ranges from Premium to Tier 3 be eco-designed based on life-cycle assessments since 2024 (milestone toward full-range eco-design by 2030); this second target is voluntary.

Resource inflows

Reference: pages 253-254.

Total weight of materials used fell to 2,867,429 t in 2025 (3,077,541 t in 2024). Biological-material weight: 737,072 t (800,791 t), of which 26% sustainably sourced (unchanged). Secondary (reused/recycled) materials: 172,003 t, or 6% of inflows (up from 5%/152,690 t in 2024). Seven raw-material categories are tracked: synthetic rubber, natural rubber, textile reinforcements, metal reinforcements, reinforcing agents, chemicals, and oils and resins. Rare earths and packaging are deemed not material; "critical materials" are defined by reference to SASB TR-AP-440a.1.

Resource outflows

Reference: page 255.

Durability: MICHELIN tires are designed for "guaranteed optimum performance from the first to the last mile," and the Group actively supported EU minimum safety standards for worn tires (see S4). Repairability: "At present, there is no particular rating system in place to assess tire repairability." Recyclable content: "as in 2024, the Group publishes a 100% rate of recyclable content in its tires," based on BlackCycle (rubber) and WhiteCycle (textile) research plus long-established metal reuse in metallurgical processes; tire packaging is not material, so a packaging-recyclability rate is not applicable.

Anticipated financial effects from resource use and circular economy

Reference: pages 187, 251.

Section 4.6.3.2 states directly: "The Group invested EUR34 million in resource circularity projects in 2025 (EUR12 million in 2024) and plans to spend over EUR250 million more over the next five years (up from the EUR200 million published in 2024)." The Group-wide financial-resources table (section 4.1.4.3) confirms the same figures under the "E5 - Resource use and circular economy" line, alongside a separate EUR60 million 2025 commitment to the ResiCare bio-sourced molecule described under E5-2.

Policies related to own workforce

Reference: page 262.

Workforce strategy is overseen by the Corporate Personnel Department (led by the Chief Personnel Officer, a Group Executive Committee member) through seven policies mapped to specific IROs and governance mechanisms: (1) Recruitment and hiring, (2) People development, (3) Employee and team compensation, (4) Diversity, equity and inclusion (DEI), (5) Employee relations, (6) Health, safety, quality of worklife, and (7) Anti-harassment. These are supported by the ICARE leadership model (Inspiring, Create trust, Awareness, Results, Empowerment) and grounded in ILO fundamental conventions, the UN Guiding Principles and the Universal Declaration of Human Rights.

Processes for engaging with own workforce

Reference: page 263.

Employee engagement is measured through the annual global "Moving Forward Together" survey, whose long-term engagement rate (four survey questions) rose from 80% in 2019 to 84.4% in 2025 (down 0.3 points from 2024, near the 2030 target of 85%). Formal representative dialogue runs through the European Works Council (CEEM, set up 1999, met twice in 2025, revising its internal rules) and the Global Works Council (set up 2020 with IndustriAll, meets annually). Michelin has been a member of the OECD/ILO Global Deal initiative since 2017 to strengthen social dialogue.

Remediation channels for own workforce

Reference: pages 263, 266.

Employees can confidentially raise health-and-safety or other concerns through direct/other managers, the ethics hotline, employee representatives, the unit's personnel manager, or the Medical Department, "without fear of reprisal." The single Group-wide whistleblowing system (in place since 2021, available in 30 languages) is accessible to employees, contractor employees and temporary workers; substantiated alerts trigger action plans with remedial measures and/or disciplinary sanctions up to dismissal, decided by the Regional Ethics Committees.

Taking action on material impacts on own workforce

Reference: pages 264-267.

On the "adequate wage and social protection floor" material impact: the Fair Wage Network "Living Wage Global Employer" certification (held since February 2024) and the Michelin One Care program (minimum 14 weeks maternity/4 weeks paternity leave at full pay, healthcare cover including maternity/outpatient care, and a death benefit of at least one year's salary from day one). On health and safety: a dedicated Employee Health and Safety Governance body (co-chaired by the Chief Personnel Officer and EVP Manufacturing), "Life Saving Rules," and EUR46 million committed to workforce health and safety in 2025 (EUR56 million in 2024), with over EUR150 million budgeted over five years.

Targets related to own workforce

Reference: page 263.

The employee-engagement target, tracked via the Moving Forward Together survey's long-term engagement rate, stands at 84.4% in 2025 against a 2030 target of 85% (up from an 80% baseline in 2019). This is the numeric target the Group's own ESRS content index maps to S1-5, distinct from the qualitative wage/safety commitments described under S1-1/S1-4.

Characteristics of employees

Reference: page 270.

Total workforce at December 31, 2025: 122,586 (129,832 in 2024), of whom 99,518 male, 25,583 female. By region: Europe 60,621 (62,239 in 2024), Americas 33,602 (36,306), Africa-Asia-Pacific 28,363 (31,287). France and the United States are the two host countries exceeding 10% of Group employees (20,872 and 18,083 respectively). Staff turnover: 12% in 2025 (11% in 2024); of 123,832 employees at January 1, 2025, 14,612 left during the year, including 6,764 voluntary separations, 6,051 non-voluntary, 1,648 retirements and 149 deaths.

Adequate wages

Reference: page 271.

"All Group employees are paid an adequate wage as defined in the ESRS S1-10-69 metric." Since 2023 the Group has sought Fair Wage Network certification: per the December 2024 certificate, 100% of covered employees are paid at least the Living Wage defined by the Fair Wage Network. Allowing for the lag between certification and the reporting period, 99.8% of Group employees were paid a Living Wage in 2025 (96.5% in 2024).

Training and skills development metrics

Reference: page 271.

"In 2025, 44 hours of training were provided per employee, calculated by dividing the total number of training hours for Group employees by the average number of Group employees in 2025." The metric is calculated for employees covered by the Group's HR information system (InTouch), which reached 89% of Group employees in 2025; only courses completed during the reporting year are counted, including courses started in 2024 and finished in 2025.

Health and safety metrics

Reference: pages 271-272.

69% of Group employees and temp agency workers were covered by a recognized health and safety management system (ISO 45001 or the Group's SMEP system) with no major compliance breaches in 2025 (68% in 2024). The Total Recordable Incident Rate (TRIR) was 4.48 in 2025 (1,041 work-related accidents), down from 5.01 in 2024, against a 2030 target of below 2.5. Work-related accidents resulted in two fatalities in 2025 (none in 2024): one industrial-site accident and one off-site traffic accident; two commuting-accident fatalities were excluded per methodology.

Incidents, complaints and severe human rights impacts

Reference: page 272.

129 confirmed discrimination incidents in 2025 (including harassment), down from 159 in 2024, reported to the Group's whistleblowing system. 1,376 grievances concerning worker or human rights violations (1,481 in 2024), spanning bullying, sexual harassment, inappropriate behavior, human rights, health and safety, personal data protection, unresolved complex employee-relations issues, reprisals, and violence/threats.

Policies related to value chain workers

Reference: pages 274-275.

Two policies address human-rights risk in the value chain, owned by the Chief Procurement Officer: the Sustainable Purchasing Policy (updated 2024, covering all Tier 1 suppliers) and the Sustainable Natural Rubber Policy (updated 2021, covering own operations, joint ventures and the upstream supply chain, built on five pillars including respect for people). Since 2012, the Michelin Purchasing Principles (supplier code of conduct) mandate compliance with forced-labor, child-labor and employee-safety requirements aligned to ILO standards, embedded in all contracts.

Processes for engaging with value chain workers

Reference: page 275.

Three engagement channels for natural-rubber value-chain workers: (1) biennial stakeholder consultations (NGOs, CIRAD, customers, suppliers and, from 2025, investors) - the fourth meeting was held in early 2025; (2) the Global Platform for Sustainable Natural Rubber (GPSNR), of which Michelin is a founding member; and (3) the RubberWay mobile-app mapping tool, through which supply-chain stakeholders (processing plants, brokers, plantations, smallholders) answer questionnaires on human rights, environment, agricultural training and market transparency.

Remediation processes for value chain workers

Reference: page 276.

Remedial actions are approved by the Human Rights Governance body or, for natural rubber, the Sustainable Natural Rubber Committee, defined case-by-case once a negative impact is confirmed. The ethics hotline (phone and secure website, independently hosted) is open to value-chain workers, customers, suppliers and other outside stakeholders. In the natural rubber chain, the GPSNR grievance mechanism is also available, and the Natural Rubber Stakeholders Committee can escalate concerns. Failure to deploy remedial measures may result in scale-back, suspension or termination of the business relationship.

Taking action on material impacts on value chain workers

Reference: pages 276-278.

Prevention/mitigation levers: contractual CSR-assessment and audit rights over suppliers; RubberWay risk mapping; EcoVadis-based third-party CSR assessments of Tier 1 suppliers with a pass threshold on human-rights scoring and biannual review; training (human-rights webinars, buyer training, field-project skills development for smallholders). Positive-impact field projects in 2025: CASCADE (Indonesia, with Porsche), RIVER (Sri Lanka), MAHAKAM (Indonesia) and HARVEST (Thailand). Recognition: EcoVadis Responsible Purchasing score of 94/100 (top 1% of industry) and No.1 tiremaker ranking on SPOTT (80% score) for the fourth consecutive year. The report also discloses that in H1 2025, press allegations of sexual coercion by local plantation staff at a Liberian natural-rubber supplier surfaced; Michelin states it had no prior knowledge, condemns the conduct, and took measures it deemed necessary.

Targets for workers in the value chain

Reference: page 278.

Three targets, each versus a stated baseline: (1) percentage of suppliers whose human-rights CSR-maturity score meets Group standards - 85% (2019 baseline) -> 94% (2025) -> 95% (2030 target); (2) percentage of natural rubber volumes assessed for human-rights compliance via RubberWay - 7% (2018 baseline) -> 86% (2025) -> 80% (2025 target, already exceeded); (3) number of village smallholders reporting improved working conditions/livelihoods - 467 (2022 baseline) -> 10,456 (2025) -> 30,000 (2030 target).

Policies related to consumers and end-users

Reference: pages 283-284.

The Group Quality Policy underpins the "Customer Promise Guarantee" quality process, applied across all host countries. It is supported by a formal Quality Statement and overseen through the Product Market Performance Monitoring Board, which reviews the tracking system three times a year for consistency with policy provisions.

Processes for engaging with consumers and end-users

Reference: page 283.

The Group tracks a Net Promoter Score-based "Partner NPS" (weighted average of OEM and dealer clusters) since 2018: 45.5 in 2025 (40.3 in 2020 baseline), against a Group target of +10 points over 2020-2030 from a 50.6 NPS base for Original Equipment passenger-car tires. Dedicated Customer Engineering Support teams and customer rooms near key markets capture dissatisfaction and route it to Quality Platforms for analysis and response.

Remediation channels for consumers and end-users

Reference: pages 281-282.

Where a product exposes customers to a potential or proven safety risk, the relevant Quality Platform initiates a process supervised by the Corporate Quality Department to assess impact and, if warranted, recall the product. In 2025, three voluntary recalls were issued, covering 92,933 products of the roughly 180 million manufactured annually - each specifying the model, manufacture date, defect description, risk assessment, root cause and corrective action, with regulators, automakers, wholesalers, dealers and customers informed and campaign effectiveness tracked by the Quality Department.

Taking action on material impacts on consumers and end-users

Reference: page 283.

Michelin actively supported EU minimum tire performance standards, including participating in the UN working group that developed regulation R117-04 introducing, from 2024, a minimum wet-grip standard for worn tires still within the legal wear limit - addressing the fact that wet-grip performance declines with wear even though rolling resistance and noise remain stable or improve. Data-driven services (EFFITIRES automated inspection, MICHELIN Connected Fleet, MICHELIN Mobility Intelligence) cover more than a million vehicles under contract and combine safety, productivity and CO2e reduction outcomes.

Targets related to consumers and end-users

Reference: page 283.

The Partner NPS target: +10 points over 2020-2030 versus the 2020 baseline of 40.3 (50.6 for the OEM passenger-car sub-segment); the 2025 actual stood at 45.5. This customer-value objective is tracked in the Group's strategic scorecard alongside the underlying safety and quality processes described under S4-1/S4-3.

Business conduct policies and corporate culture

Reference: page 287.

Two reference documents anchor ethics: the Michelin Code of Ethics ("Acting Ethically Every Day," reviewed/expanded in 2021 and again in 2025 to strengthen human-rights, environment and AI-ethics commitments, translated into 21 languages) and the Anti-Corruption Code of Conduct (introduced 2015, updated 2020 and 2025). Both apply to all employees and anyone working on Group sites or on the Group's behalf, and cover gifts/invitations, export controls, competition law, conflicts of interest, donations, insider trading, anti-fraud/anti-corruption, data protection and supplier relations. A Compliance Support Group (CSG) in the Corporate Legal Department leads deployment, overseen by Regional and Group Ethics Committees.

Prevention and detection of corruption and bribery

Reference: pages 289, 292.

The Anti-Corruption Compliance Program (ACCP), introduced 2018 under France's Sapin II Act and re-approved by the Group Ethics Committee (latest update December 2024), rests on: top-management commitment, the CSG compliance team with regional relay officers, a Sapin-II-based corruption risk map (updated three Regions per year in 2024-2026), third-party due-diligence screening, the Code of Ethics and Anti-Corruption Code of Conduct, mandatory e-learning renewed every two years for at-risk functions, the whistleblowing hotline, control procedures (anti-corruption accounting audits), and a disciplinary-measures tracking system. Purchasing, sales, customs, logistics, M&A and public affairs are named as the most at-risk functions.

Targets related to business conduct

Reported under MDR-T in the FY2025 statement, prepared under the 2023 ESRS, where business-conduct targets were not yet a standalone G1-3 disclosure requirement.

Reference: page 293.

"The Group's target for the anti-corruption training attendance rate is at least 95% by the end of 2026." Against this, 89% of employees in at-risk functions received anti-corruption training between January 1, 2024 and December 31, 2025 (up from 79% in the prior two-year window), tracked as a formal KPI under the Anti-Corruption Compliance Program.

Confirmed incidents of corruption or bribery

Reference: page 293.

"In 2025, as in 2024, there were no convictions, and consequently no fines paid for the violation of anti-corruption laws in the Group," tracked by each Regional Compliance Officer. The Group frames this as evidence of its zero-tolerance policy, though the absence of confirmed incidents is a lagging indicator rather than a direct measure of prevention-program effectiveness.