Charitable and Political Contributions
Michelin prohibits any kind of political donations or contributions.
The Group favors involvement in charitable endeavors that enhance the communities and people with which it interacts and on which it may have an impact.
Definitions
Charitable contributions are donations made to a non-profit organization, charity, private or public foundation. Such donations may be in the form of cash, real property, goods, securities or other items of value.
Political contributions are funds or resources donated directly or indirectly to political parties, candidates for office, or PACs (political action committees).
Guiding Principles
Political donations & contributions
Michelin prohibits political donations and contributions, directly or indirectly through third party intermediary.
The Group considers that it may legitimately express its point of view, with integrity, in explaining to public decision-makers its positions on matters of interest to the Group. The exchanges are made in accordance with the principles of honesty and in the interest of our stakeholders, such as shareholders, customers, partners, employees and the relevant jurisdiction (country, province, state, municipality, etc.).
It is also prohibited for third parties (as, by example, directors, intermediaries or external consultants), to provide political donations or contributions on behalf of the Group, or in its name, notably to obtain any advantage whatever the form.
Charitable donations and contributions
The Group can support causes, that embody values shared by the Group and that are in line with Group’s strategy.
Charitable contributions are allowed if they are:
- Respecting the principes of this Code and the Anticorruption Code of Conduct,
- Done through the Michelin Group Fundation or in Regions by the teams in charge
- Recorded in a specific register,
- Allowed by the applicable laws;
- Publicly disclosed according to applicable law, whenever required, and
- Authorized by a written policy of the Region, the Group, or the Entity (for example, the Gifts and Invitations policy), or specifically authorized in writing and in advance by the Region Director
Third parties (for example, agents, intermediaries, external consultants) are strictly forbidden to make charitable donations or contributions in the name of or on behalf of the Group, without the prior written approval of the Group.
Do: I must
- Before a charitable contribution is made by an entity of the Group, make sure that it conforms to this Code and to applicable law.
- Consult my manager, the Region Compliance Officer or the Legal Department if I have any doubt.
Don't: I must not
- Use Group funds or resources to make a political contribution or make any political contribution in the Group’s name, directly or indirectly through an intermediary.
- Distribute in the workplace any signs or slogans in favor of a political candidate.
- Make a charitable contribution that could be interpreted as a bribe. If I have a doubt, I consult the sections of this Code concerning Gifts and Invitations and Fighting Corruption, and/or I contact the Legal Department.
Practical case 1
You are member of the leadership team of a factory that has a significant economic impact on the neighboring community. In the course of a re-election campaign for a political office that represents the territory in which the factory is located, the incumbent contacts you. They want to organize a visit to the factory, with local media, to announce the introduction of a proposed law favorable to industry, including Michelin. How do you react?
Michelin does permit visits to facilities to allow officials to learn about its operations. However, such visits are discouraged during political campaign seasons. You should immediately contact the public affairs department, the Region or country Compliance Officer or the Legal Department to obtain their advice before responding to the request.
Practical case 2
You believe your site should lend support to a local event to raise money for a charity that benefits the community. Whom should you contact to explore this possibility?
You should contact your local public affairs department.
