Fighting Fraud
Fraud endangers Michelin's activities as well as its image and reputation.
Fraud and dishonesty, like any criminally reprehensible behavior, are strictly prohibited at Michelin; they can engage the civil or criminal liability of the employee. Any proven fraud is subject to a disciplinary sanction, in accordance with applicable law.
Absolute vigilance is required with respect to the communication of sensitive data to persons outside the company which could allow an external third party to commit fraud.
Definition
Fraud is a willful and intentional act of dishonesty, deception or breach of trust, committed with a view to illegally obtaining a financial or other advantage, whether for a Group employee or for the benefit of a third party or a company outside the Group. There are several categories of fraud:
- Misappropriation of assets: goods and money.
- Corruption, whether active or passive.
- Falsification of financial statements.
Fraud can be committed by an employee working for the Group. It can also be carried out by a person or an organization outside the Group.
Guiding Principles
The promotion of a culture of integrity at all levels of the Group (clear managerial messages on expected behavior and zero tolerance) and the implementation of effective risk control procedures limit the risk of fraud.
Michelin has implemented an internal control system for all Group companies.
This system is based on means, behavior, procedures and action plans adapted to the specific characteristics of each company which aims to:
- Contribute to the control of activities, the efficiency of operations and the efficient use of resources,
- Appropriately take into account significant risks, whether operational, financial or compliance.
This system aims more particularly to ensure:
- Compliance with laws and regulations;
- The application of instructions and guidelines set by the Corporate Directions or the management of the Group;
- The proper functioning of the Group's internal processes, in particular those contributing to the protection of its assets;
- The reliability of financial information.
The manager is a key player in this system:
- They develop a culture of integrity in their team;
- They communicate the fundamental principles of the Group;
- They remain vigilant on the risks of fraud that may arise in their Entity;
- They impose sanctions when fraud by an employee is proven.
Do: I must
To prevent fraud
- Know and respect the internal control rules defined in my Entity, in particular those relating to the segregation of duties.
- Define and implement corrective actions when a control weakness has been detected.
- Reserve the tools and resources made available by the Group (bank card; computer; tools) for professional use, except where specifically authorized by a Region or country policy.
- Report to my manager any urgent request for modification or communication of sensitive data.
- Alert my manager to recurring difficulties in applying a procedure.
In case of suspicion of fraud
- Alert my manager or contact the Michelin Ethics Line.
- Systematically involve the Regional Security Director, who is the only person authorized to carry out investigations.
When the fraud is proven
- Identify any weaknesses in the control system and correct them.
- Alert my hierarchy to the mechanism of fraud in order to prevent its reproduction in other Entities.
- Sanction an employee who has committed fraud in consultation with the Personnel Department.
Don't: I must not
To prevent fraud
- Bypass a procedure because everyone is doing it.
- Communicate my information system access passwords to third parties.
In case of suspicion of fraud
- Seek to carry out an investigation on my own.
Practical case 1
A supplier asks you to urgently pay an invoice to a new bank account with contact details attached. What should you do?
Many frauds have been committed by people impersonating a supplier.
You inform your manager. You follow the procedure of the Purchasing Department to confirm this request.
Practical case 2
You are the sole recipient of a signed email from a Michelin executive requesting sensitive information. Should you respond?
An unusual request, even an internal one, can be a sign of an attempted identity theft fraud. You transfer it to the Security Department of your Entity to ensure the procedure to follow.
Practical case 3
Your manager asks you to defer the accounting of an expense to the following year (for example, the value of unsellable or unusable product that will be destroyed). What should you do?
You should refuse to do this and remind your manager of the accounting rules and procedures of the Group. If your manager insists, contact your functional manager. If the situation persists, you should make an alert on the Ethics Line.
