ADP CSR Report 2019

Exemplary operations

Controlling risks and acting ethically

OUR ACTIONS

Strengthen the "Ethics and Compliance" culture Our "Ethics and Compliance" action plan involves a change of culture that, despite being outside the remit

Combat corruption and tax evasion Our strategy to combat tax evasion is aligned with OECD standards aimed at locating and taxing income where the activity is conducted and improving the transparency of information. We reject all investments in tax havens and countries considered to be fiscally uncooperative if they are not motivated by real business reasons. In 2019, we drew up a map of the risk of corruption in France and internationally , accompanied by recommendations and follow-up. We have educated and trained our entire Executive Committee and the senior management at all our subsidiaries. The corruption risk is also taken into account prior to all contract signings.

In 2020, we will continue our work in anti-corruption and the duty of diligence, as well as our international harmonisation efforts. We will continue to implement a single multilingual code of ethics in all our operations around the world, along with local roadmaps to foster transparency. Ensure data security As part of Aéroports de Paris SA's many activities, over 200 personal data processing operations have been recorded in the regulatory

register under the GDPR (General Data Protection Regulation). Examples include baggage handling, financial assistance for soundproofing by local residents, customer loyalty management and employee payroll management. A data protection officer has been appointed to oversee the compliance of these processing operations. The Group's compliance with the GDPR continued in 2019, including a campaign on informing and educating staff members about personal data protection issues.

of procedures, is based on: exemplary management; the map of corruption risks; dedicated governance, with a department reporting to the

Chairman & Chief Executive Officer, an ethics committee created in 2019 and a strengthened network of "Ethics and Compliance" officers; an "Ethics and Compliance" code of conduct distributed to all staff members and available online at any time; procedures for handling conflicts of interest, gifts and invitations; a lobbying charter to govern the representation of interests; an alert system accessible to all Group staff members and our suppliers; a barometer measuring annual changes in the culture of ethics and compliance, particularly the level of confidence in the alert system; educating and training our staff members, in France and abroad, through new e-learning modules rolled out alongside in-person training.

INTERNATIONAL

AIG and TAV Airports have conducted an inventory of local regulations in all areas of the ISO 26000 standard: this gave them the opportunity to analyse their practices and identify their

risks in the areas of human rights, labour relations and working conditions, and the environment. Various working groups are now tasked with defining improvement actions.

In Madagascar, Ravinala Airport (RA) has adopted a code of conduct on transparency and ethics, which must be applied by all staff members as part of a "zero tolerance" mindset.

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