Code de conduite Anglais 2023

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ETHICS & COMPLIANCE

GROUPE ADP CODE OF CONDUCT

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

EDITORIAL

WHY GROUPE ADP NEEDS AN ETHICS & COMPLIANCE PROGRAM

ETHICS IMPULSE KEEP US ON TRACK!

ETHICS & COMPLIANCE: OUR DEFINITION For Groupe ADP, ethics and compliance involve both compliance with laws and regulations and compliance with the Group's values of Responsibility and Hospitality.

For Groupe ADP, ethics and compliance include the adherence to the laws and regulations of the countries where the group is present, and to values of Responsibility and Hospitality. In order to effect changes in procedures, ethics and compliance must first be firmly anchored in cultural change. Each employee commits to this cultural change by applying

E thics and compliance are a driver of trust and therefore performance for our Group and its stakeholders! They account for 12 – 18% of our extra- financial rating, which has a direct impact on our capacity for growth. Ethics and compliance are an imponderable for Groupe ADP and must be our trademark in our business. This is why Groupe ADP is deploying a global program in which information, awareness and training will act as key tools to help you to implement an approach in your daily working life. A strong ethics and compliance program helps preserve a positive corporate image, while limiting the risks to which the Group may be exposed. It is therefore a factor of confidence for our employees, our customers and our suppliers and a guarantee of good governance for our shareholders. The principles set out in this Code are intended to help each employee in their daily professional practices.

Our rules on ethics and compliance rest on three fundamental principles that must guide our work: responsibility, integrity, and respect. Failure to comply with these rules may lead to disciplinary action. It is therefore very important to discuss any sensitive situations with your managers or with the Ethics & Compliance officer (see page 36). Reflecting on and discussing one's practice and these issues are crucial steps in developing the right reflexes, finding appropriate solutions, detecting potentially risky situations, and escalating them properly. Together, we can help the company to grow and to evolve. Our involvement keeps on track!

Groupe ADP’s values in their daily working life. Having good ethics impulse keeps on track!

LOYALTY: A TWO-WAY COMMITMENT

This duty covers a wide range of actions which might cause unlawful harm to one of the parties, carried out by either the employee (do not harm or disparage your employer, customers, suppliers, partners etc., do not disclose confidential information, do not take up a competing job without prior authorization, and so on) or the employer (pay wages owed and stick to deadlines, provide employees with the agreed-upon job, provide employees with sufficient resources to carry out the work expected of them, and so on).

Signing an employment contract (open-ended, fixed-term, an apprenticeship, etc.) binds both the employee and the employer to a duty of loyalty which requires that both parties behave with integrity in the execution of their work. THE DUTY OF LOYALTY APPLIES: • Throughout the term of the work contract, including periods of suspension (e.g. time off work, vacations), • To all employees in all positions, • With the exception of any work contract clauses to the contrary.

codeofconduct.groupeadp.fr

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

Ethics and compliance have become a universal requirement in business dealings. Similarly, ethics and compliance violations can lead to being excluded from certain markets (the World Bank, etc.) or to prohibitions against borrowing from certain banks in order to fuel our growth. All our stakeholders are attentive to our approach to ethics and compliance. The values of responsibility and hospitality are success factors for the Group. Everyone is an actor and ambassador of Ethics and Compliance at their own level and in their own missions. This responsibility of each employee is the strength of the Group: it is a strong marker that feeds its performance. The rules of this Code must therefore be applied by each employee

and by any person acting for or on behalf of the company (subcontractors, etc.). Employees must also ensure that the people under their responsibility respect the principles. Hospitality is also a key subject in the Ethical culture. This value must first and foremost be embodied internally within the teams and then be perceived on our platforms by our passengers. The aim of our ethics and compliance mechanism is to all of Groupe ADP's employees but also the company.

EXAMPLE OF SANCTIONS FOR CORRUPTION

• AIRBUS CONDEMNATION: $2.9 billion in 2020.

CODE OF CONDUCT: REASONING AND APPLICATION

ETHICS & COMPLIANCE PROGRAM: DEVELOPMENT AND STEERING The Ethics & Data Protection Department and the Legal & Insurance Department are working together at the Group level to manage the program. They will also work together to implement the program, with support from the Ethics & Compliance officers within our subsidiaries and in collaboration with relay- persons in our cross-cutting divisions.

Groupe ADP operates in a highly demanding world in which apparently minor misbehaviors could have extremely costly consequences (examples include fines, prison sentences, business sanctions, damage to our reputation, etc.). Groupe ADP has therefore decided to clearly set out its rules of conduct which, while they cannot cover every eventuality, nonetheless serve to protect both the company and its employees. This code of conduct applies to all Groupe ADP employees. The purpose of the code is to spotlight the major Ethics and Compliance issues providing concrete examples to help our employees take ownership of the principles and apply them in all aspects of their work life.

Within the framework of a control, whatever its nature and type (internal control, audit, internal investigation, control of authorities...), each employee solicited must be cooperative and must actively cooperate.

REACHING OUT WITH QUESTIONS OR IN SENSITIVE SITUATIONS It is vital that you share your concerns

if you have questions or encounter a sensitive situation! Reaching out and discussing these issues sheds light on them, allows us to detect any risks and helps us to find appropriate solutions with your manager (see page 36). We have also set up a whistleblowing system**. You can find the alert treatment charter on the whistleblowing platform.

** https://alert.groupeadp.fr

CODE OF CONDUCT GROUPE ADP

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Furthermore, Groupe ADP, Aéroports de Paris SA and TAV Airports became a signatory of the 10 Principles of the Global Compact in 2003 on which it relies for the deployment of its policies.

THE 10 PRINCIPLES OF THE GLOBAL COMPACT

Human Rights Support and respect the protection of internationally proclaimed human rights.

The elimination of all forms of forced and compulsory labour. Environment Support a precautionary approach to environmental challenges. Undertake initiatives to promote greater environmental responsibility. Encourage the development and dissemination of environmentally- friendly technology. Anti-Corruption Work against corruption in all its forms, including extortion and bribery.

CONTENTS

Compliance with laws and regulations ............................................................................ 8 Combating breaches of integrity ............................................................................................... 10 Preventing corruption ............................................................................................................................................. 12 Preventing influence peddling .......................................................................................................... 16 Guarding against gifts, hospitalities and benefits ............................ 18 Detecting and dealing with conflicts of interests ........................... 20 Compliance with the code by partners .................................................................... 22 Safeguarding personal data and information ........................................... 23 Upholding the principles of free competition and fighting collusive and coercive practices .......................................... 28 Respecting our employees, colleagues and partners ................................................................................................................................................................................. 34 Dealing with sensitive situations: the group's alert system and the whistleblower protection ........................................................................................................................................................................................... 40 Glossary ................................................................................................................................................................................................... 42

Make sure that there is no complicity in human rights abuses. Labour Uphold the freedom of association and the effective recognition of the right to collective bargaining. The elimination of discrimination in respect of employment and occupation.

Ensure the effective abolition of child labour.

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For example:

COMPLIANCE WITH LAWS AND REGULATIONS

I have just been promoted to a new position. My new job involves the management of an airport activity ensuring the accessibility of passengers, and my team just let me know that we must comply with a specific regulation that I am not familiar with.

I am a Terminal Security Manager. A public official has informed me that my procedures must allow State agents to proceed through the security checkpoint area on the basis of their uniform alone and without having to show a badge. Although

Ethics exist in a close relationship with compliance with laws and regulations. At all times, every employee must ensure their strict adhe- rence to laws and regulations, as well as to any contractual obligations arising during the course of their work.

I cannot find anything relating to this in the applicable regulation,

What should I do?

I comply with the request as it comes from one of a government department.

You should discuss the situation with your manager, and ask your legal division to provide the relevant information.

Is my decision correct?

LAWS AND REGULATIONS

BEST PRACTICES

If this type of exemption is not provided for by law, a State official is not empowered to ask for it. Complying with the official’s request would break the law and endanger the company. You should reach out to the Legal Department, who can tell you whether such a law exists and assist you in framing a response for the official making the request.

 With your manager, discuss the Legal knowledge required by your position.  If your position requires it, learn at least the basics of the relevant laws and regulations.  Make use of the legal monitoring tool of your company if available, and/or ask your Legal Department.  Comply with applicable delegations.

FOCUS: INTERNATIONAL SANCTIONS

BE AWARE

STRICTLY FORBIDDEN

International sanctions (or embargoes) may be imposed on certain countries, individuals or sectors. All Group employees are therefore required to apply the Group International Sanctions Procedure. Any failure to comply with international sanctions regulations may result in significant civil and criminal penalties for the employee and the Group. It is therefore essential to contact the Legal Department and the Ethics and Compliance Officer before any project or contract in case of doubt.

THE PROS Regulatory compliance enables effective risk management and protects employees from any form of breach of probity. It is imperative to preserve the trust of our stakeholders in our business relationships

If the legality of a document is in question, follow the procedures:  Discuss the issue with your manager and colleagues in your Division.  Depending on the issue, reach out to the Legal Department, the Group Ethics & Compliance officer, and/or your HR manager.

 Making any decision that carries legal risks without prior consultation with your manager or the Legal Department.  Making a commitment, or committing

the company, if there is any doubt regarding compliance with laws and regulations by the company or its partners.

which are based on transparency.

CODE OF CONDUCT GROUPE ADP

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COMBATING BREACHES OF INTEGRITY

For example:

A breach of integrity is any act of deception designed to gain an improper or illegal advantage. They may be subject to prosecution. Examples include theft, extortion, embezzlement, abuse of trust, concealment, money laundering, corruption (see page 12), influence peddling (see page 16), offence of favoritism, unlawful taking of interest, misappropriation of public funds, insider dealing or the misuse of company assets, concussion, collusion, coercive practices (see page 28) obstructionist maneuvers and usurpation of identity/of office.

I am an accountant. One Friday at 4 PM, I get a phone call from someone claiming to be the Chief Executive Officer, instructing me to make an immediate funds transfer to an account, and giving me the details of the account.

I am away on mission and would like to bring a present back for my kids. I use my Groupe ADP bank card to pay for it.

Is this acceptable behavior?

Should I comply?

This is an abuse of trust. A business bank card may only be used for work- related purposes.

This could be an attempted fraud, commonly known as “CEO fraud”. I must make sure I follow the correct procedure, including letting my manager know and starting all required validation processes.

BEST PRACTICES

BE AWARE  In cases of suspected fraud, be sure to inform your manager, the Legal Department, or the Group’s Ethics & Compliance officer.

Every employee should be proactive in preventing fraudulent behavior:  Enforce all applicable instructions and procedures.  Protect the company’s assets and inventory (facilities, equipment, etc.).  Track all actions and retain all supporting documents.

STRICTLY FORBIDDEN  Agreeing to ignore the company’s procedures.

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

PREVENTING CORRUPTION Corruption consists of procuring an advantage (gifts, hospitality, money, information, services, and so on) for any public or private person in order to induce them to act or refrain from acting. Corruption can be active (on the corrupter’s part) or passive (on the part of the person being corrupted). Intent alone can be enough to qualify as an offence! Those involved (those corrupting and those corrupted) are not the only ones liable: the company and its representatives are also liable in such cases. Furthermore corruption damages their reputation. In order to effectively prevent corruption, the following principles must be learned and applied by all employees: No compromise with compliance. Groupe ADP will always be on the side of ethical employees who refuse to take part in any form of corruption or bribery.

For example:

I work at an airport. A local airline manager offers me a free plane ticket or upgrade if I agree to hire his son.

I am a baggage process expert. An equipment supplier for baggage handling systems offers me VIP seats for a major sports event if I provide them with technical data regarding our handling systems.

Is this acceptable?

This is bribery attempt that is punishable by law and by Groupe ADP. I refuse the offer. I also inform my manager or the Ethics & Compliance officer.

BEST PRACTICES  Carry out daily operations with openness, equity and honesty, and in compliance with Groupe ADP's standard operating procedures.  Let our partners know about our commitment to fight corruption.  In cases of suspected or attempted corruption, inform your manager or the Group’s Ethics & Compliance officer (see page 36). BE AWARE  Feeling indebted after having received some advantage or benefit from a partner.  Dealing with intermediaries (or business ‘introducers’).  Accepting or offering a gift or hospitality without analyzing the context (see page 18).

STRICTLY FORBIDDEN

 Offering or accepting bribes, gifts, hospitalities, services etc. in order to obtain a call for tenders or in exchange for confidential company information.  Agreeing to use an intermediary specified by a client or prospect in order to secure a contract.  Approving receipt of a service or order greater than what was actually provided/ delivered in order to obtain a benefit from the provider, either for oneself or for others.  Considering a business relationship (see procedure on third party assessment) without first checking up on the third party in question (suppliers, customers, etc.) 1 .  Making facilitation payments in order to ease or speed up obtaining authorizations (see Focus "Bribery of public officials").

PENALTIES IN FRANCE

FOR THE COMPANY • From € 5 million to 30% of the company’s turnover (french Sapin 2 law) • Being excluded from certain market awards (e.g. by the World Bank) • Prohibitions against borrowing • Damage to the company’s reputation FOR EMPLOYEES • Up to 10 years in prison • A fine of € 1 million (french Sapin 2 law) • Forfeiture of civil rights • Being prohibited from working in the relevant domain for more than 5 years

THE SINGLE EXCEPTION TO THESE PRINCIPLES a margin of tolerance applies when a person’s physical safety - or his or her relatives - is threatened. If this should happen, you should immediately inform your manager, HR manager, the Legal Department or the Ethics & Compliance Officer.

1 Third party evaluation procedure.

CODE OF CONDUCT GROUPE ADP

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FACILITATION PAYMENTS

FOCUS ON THE CORRUPTION OF PUBLIC OFFICIALS

are considered a bribe and are prohibited. It puts a company's reputation at risk and exposes it to legal risks and criminal prosecution under local and offshore laws.

Making a payment to a public official, offering them a gift to guarantee or accelerate the performance of a public act that they will have to carry out anyway, is not trivial. In many countries, facilitation payments

A public official is a person entrusted with public authority, a public service mission or invested with an elective or jurisdictional mandate. However, this notion can be understood more broadly depending on the country: it can concern the head of a public company, the head of a State monopoly or even the senior executives of any company in which the State has a dominant role. Unwavering vigilance is therefore required, especially since bribery of public officials is more severely punished and may also be subject to extraterritoriality laws such as the U.S. Foreign Corrupt Practices Act.

For example:

I am an expatriate development officer, in contact with local officials for an airport construction project. Winning this tender would allow us to access a very promising market. My interlocutors were in favor of our project and asked me to help them financially to

"support" our project with the authorities.

BEST PRACTICES

BE AWARE  Underestimating the risk of corruption of a public official because he or she is not a decision-maker, although he or she may have access to sensitive information and/or influence the final decision.  Paying less attention to lobbying activities carried out by the company or by professional organizations (see the Responsible Lobbying Charter).  Recruiting a former public official or one of his relatives without measuring the possible risk of corruption or influence peddling.

 Perform sufficient due diligence on third party public officials who are particularly exposed to the risk of corruption.  Conduct relations with public officials in accordance with the ADP Group's internal ethics and compliance system and local laws.  In case of suspicion or attempt of corruption, inform your manager or the Group's ethics and compliance officer.

This is incitement to corruption. You must immediately inform your manager, the Legal Department and/or your Ethics and Compliance Officer.

What should I do ?

SANCTIONS FOR BRIBERY OF PUBLIC OFFICIALS

IN TURKEY • Revocation of licence • Ban on participation in tenders and termination of the public procurement agreement • Administrative fines • Imprisonment of 4 to 12 years for collaborators

IN JORDAN • 2 years minimum imprisonment for collaborators IN THE USA • Combination of criminal and civil penalties • Up to $30 million per violation for companies • Up to 25 years in prison and a minimum fine of approximately $6 million for employees

STRICTLY FORBIDDEN

 Offering a public official a bribe, gift, invitation, service, etc. to win a bid, speed up a decision, obtain information, etc.  Agreeing to work with a third party proposed by a public official in order to win a contract.

 Considering entering into a business relationship with a third party without making the usual checks, on the grounds that they are recommended by a public official.

CODE OF CONDUCT GROUPE ADP

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PREVENTING INFLUENCE PEDDLING

For example:

I am working on the construction of a new airplane hangar; the authority is delaying the delivery of the building permit. I know the brother of the deputy of this authority who travels a lot. I would like to ask him to speed up, with his brother, the obtaining of the permit in exchange of a parking card of the ADP Group.

Influence peddling consists of soliciting a public person or a private person in charge of a public service mission (such as Aéroports de Paris SA) by providing them with an advantage so that they use their real or supposed influence with another person in order to obtain a favorable decision. The intention alone can be qualified as a crime. Like corruption, it can be active (on the part of the person who solicits) or passive (on the part of the person who uses his influence). The sanctions are the same as for corruption.

Is this acceptable?

This is an act of influence peddling punishable by law and by Groupe ADP.

BEST PRACTISES

BE AWARE  Allow some ambiguity in relationships with business partners.

 In accordance with the disclosure requirements for listed companies, provide only verifiable and up-to-date information.  Prohibit any behavior that could be perceived as a form of influence peddling, in particular by respecting the rules regarding gifts and invitations.  Consult the charter of responsible lobbying which frames the actions of representation of interests.  Share our commitment with our partners in our activities.

STRICLY FORBIDDEN

 Offering an advantage of any kind (money, gift, invitation, service, etc.) to an elected official, a member of an administration, etc., so that they influence an acquaintance with a view to a decision, a vote, etc., in favor of the ADP Group.  Representing interests without being mandated by the ADP Group without following the principles of the responsible lobbying charter.  Make a commitment, on behalf of the Group, to finance political parties.  Use intermediaries (business introducers) without informing the Group's Legal Department.

CODE OF CONDUCT GROUPE ADP

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GUARDING AGAINST GIFTS, HOSPITALITIES AND BENEFITS

INDICATORS 4 criteria for context analysis:

Gifts and hospitalities can easily be seen as attempts to bribe or corrupt. They must therefore remain a rare occurrence. Situations like these can expose employees and the company to the same risks. While maintaining good relationships can occasionally lead Group employees to offer or accept gifts or hospitalities, it is essential that the context of such situations be carefully examined.

1 Reach out to the Legal Department to find out whether local laws have a specific framework. 2 Note the strategic context, if present: neither accept nor offer gifts/hospitalities during calls for tenders, voting periods, negotiations, and so on. 3 Keep things on a professional level and do not cross over into private life. The following are examples of non-professional situations:  Any hospitality which includes friends or family who are not directly involved in the project.  When time at seminars and professional events includes more free time than job-related time.

4 Establish whether the value of the gifts/hospitalities is reasonable.  Reciprocity test: am I authorized to provide the same value of gifts/ hospitalities within the parameters of my job?  Whether a gift/hospitality is reasonable may also be evaluated based on local laws and income levels, a criterion that is particularly important when one is abroad. As an example, it might be 5 - 10% of an average wage in the other country.  When evaluating value, take into account all other gifts/hospitalities in the past (total them by year or by third party - see graphic below).

BEST PRACTICES

 Analyze the context in which gifts or hospitalities are offered or accepted, using the 4 criteria presented below.  Give preference to advertising gifts or to those whose value is purely symbolic.  During professional gatherings, Groupe ADP may fund transport and lodgings if it is useful and beneficial for business.  Systematically declare gifts and invitations > 60€*.  Always ask your manager for approval for all gifts/hospitalities whose value is > € 200*. BE AWARE  Avoid all gifts or hospitalities that might lead an outside observer to question the integrity of the giver or the recipient.  Avoid all gifts or hospitalities that might affect the impartiality of any decisions an employee must make in the interests of Groupe ADP.

SUMMARY

STRICTLY FORBIDDEN  Accepting: any amount of money, even as a loan or a guarantee, or the free provision of moveable assets or property, equipment, trips or other service provided by a third party, either for oneself or for one's family, friends, or colleagues.  Accepting any kind of gift or hospitality that places you in the giver’s debt in any way.  Accepting any gift or hospitality during a strategically-important time (e.g. a call for tenders).

Gifts / hospitalities > € 200 cumulative total for France or 5-10% of an average wage in other country Needs prior approval from your manager

Gifts / hospitalities > € 60 cumulative total Inform your manager

Gifts / hospitalities < € 60 cumulative total No approval required

* Cumulative per year and per third party.

CODE OF CONDUCT GROUPE ADP

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For example:

DETECTING AND DEALING WITH CONFLICTS OF INTERESTS

In my spare time, I am the vice-chairman of an airport neighbours' association. In my work at Groupe ADP, I am responsible for working on a new runway project.

I am involved in selecting a supplier. My brother works for a company that is applying.

Conflicts of interests arise when the personal interests of an employee or person close to them compete with an employee’s job description or mission as set out by the company. The employee can no longer be relied on to make impartial professional decisions. While a conflict of interests is not an offence in a majority of countries, it often arises from a sensitive situation that may lead to actual offences. A conflict of interests can arise at any time and in any situation: in dealings with an external partner, within a team, when recruiting someone you know, etc.

What should I do?

Depending on the job your brother has with that company and the financial stakes involved, there may be a conflict of interests if your brother is salesman in this company for example. The only way to decide whether the situation is acceptable or not is to discuss the situation honestly and openly with your manager, to find a solution that will protect you and Groupe ADP.

Groupe ADP respects the private lives of its employees and indeed encourages them to take part in community life and associations. However, the airport neighbours' association is leading or might lead to a conflict with the interests of Groupe ADP, you must let your manager know about it. Your manager or your Ethics & Compliance officer will advise you on the best way to proceed. if you think your involvement with

BEST PRACTICES  Carry out your duties at work in the sole and strict interests of the company, and never based on personal interest.  Know how to spot a potential or emerging conflict of interests.  Report any actual or suspected conflict of interests to your manager or Ethics & Compliance officer, and decide together on the best way to deal with the situation in order to minimize the risk to the employee and the company.

BE AWARE  Be aware of your friends, family, or employees who might have business or personal relations or even financial interests with a Groupe ADP supplier, competitor, or customer.  In some public situations (e.g. elected, associative mandate), be sure to avoid taking part in decisions relating to Groupe ADP, its subsidiaries or its joint ventures. STRICTLY FORBIDDEN  Concealing a conflict of interests that could be damaging to the Group or an employee.

CODE OF CONDUCT GROUPE ADP

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COMPLIANCE WITH THE CODE BY PARTNERS

SAFEGUARDING PERSONAL DATA AND INFORMATION

Groupe ADP attaches great importance to the relationships it maintains with its many partners. These relationships must be based on compliance with contractual obligations and rules of good conduct. The Group's partners are therefore asked to implement a set of appropriate policies aimed at preventing breaches of integrity (see the chapter entitled "Combating breaches of integrity"). In this context, the business partner may be asked for information concerning the subjects covered by this code and it may be decided to implement remedial actions in the event of a breach (audit, termination of contract, etc.). Any breach of this code must be reported through the alert system accessible to our employees and service providers via the address https://alert.groupeadp.fr.

Daily operations within Groupe ADP require the sharing and processing of a wide range of company-specific data, activities, statistics and studies. This body of information is a valuable asset. The company is at risk when data is leaked, incorrectly processed or poorly managed. Our data assets must be protected to ensure the company's future growth and competitiveness. It is vital that we protect and manage the Group’s sensitive and confidential data, whatever its type, form, or location. To this end, Groupe ADP has developed a Group Data Protection Policy*. All employees are responsible for implementing it on a daily and systematic basis. All employees must be actively involved in complying with the policy.

BEST PRACTICES  Ensure that the evaluation of the third party has been carried out before contracting in accordance with the procedure and operating mode in force.  Ensure the correct application of the remediation actions decided by the Group (questionnaire, sharing of internal Ethics and Compliance policies, contractual clauses, etc.).  Contact the Legal Department prior to any contractualization, and in particular to negotiate the Ethics and Compliance clauses.  Send Groupe ADP's code of conduct to the business partner at the beginning of the negotiations.

BE AWARE

 In the event of a suspected breach of this code or of the contract, inform the manager or the Group's ethics and compliance officer in order to deal with the situation (additional information or questionnaire, audit, breach of contract, etc.). STRICLY FORBIDDEN  Signing a contract without first evaluating the third party or consulting the Legal Department and the Ethics Officer.  Ignore the recommendations of the Ethics Officer.

THE PROS The security of information enables us to preserve the digital ecosystem in order to protect the Group and all its stakeholders, as well as its image and reputation. In this context, the protection of personal data reflects the commitment to offer our stakeholders secure services that respect their rights to their data (confidentiality, privacy). Transparency, quality, integrity and security of personal data are factors of trust for responsible personal data.

* for more information, please contact the Division in charge of Safety and risk management.

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SPECIAL CASE: PERSONAL DATA

Any information which may be used to identify a specific individual (e.g. first & last name), or which allows a person to be identified by cross-referencing several data points (phone number, registration number, badge number, etc.) is considered personal data. A subset of this is considered sensitive or confidential data (biometric data, health information, etc.). The use of such personal data must comply with the principles of Groupe ADP (see table below).

In some countries, it also implies complying with all applicable regulations (General Data Protection Regulation - GDPR for entities located in the EEA 1 and the Turkish Data Protection Act - KVKK Law for entities located in Turkey… ). In this case, for these entities, it is essential that their processing be reported in the register required by the regulations. The teams dedicated to Data Protection are your privileged

PENALTIES FOR FAILING TO PROTECT PERSONAL DATA

COMMON OFFENCES • 2% of the Group’s consolidated turnover for common offences. Applies to: breach

contacts to help you ensure compliance with regulations.

of duty by the processing manager and sub-contractor, failure to comply with obligations by the company responsible for monitoring adherence to the code of conduct.

• Failure to comply with basic principles, personal rights, or obligations during data-transfers to other countries or to international organizations: 4% of the Group’s consolidated turnover for the previous year.

4 PERSONAL DATA PROTECTION GROUP PRINCIPLES

1 - Proportionality each entity may only process personal data for a specific, legal and legitimate purpose. The personal data processed must be relevant and strictly necessary in relation to the defined purpose ; 2 - Limitation of retention the retention period must be fixed according to the type of personal data processed and the defined purpose. The data must then be deleted or anonymized ; 3 - Security each entity must guarantee the integrity, availability and confidentiality of the personal data processed. In particular, it must ensure that only authorized persons have access to personal data ; 4 - Designate a point of contact each entity must designate a contact person for any question relating to the protection of personal data, whether from the persons concerned or from other entities of the Group.

FOR OTHER ENTITES • Other sanctions may exist according to specific regulations.

1 European Economic Aera.

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SAFEGUARDING PERSONAL DATA AND INFORMATION (CONTINUED)

BEST PRACTICES  Maintain the highest levels of discretion and confidentiality when dealing with company- related data, whether inside or outside the company.  Assess the confidentiality of the information contained in a given document and record its level on that document.  Ensure that you have a secure computer connection that complies with the company's or group's policies.  Maintain traceability of exchanges of the most sensitive documents.  Store and destroy the documents you deal with based on their confidentiality level (reinforced cupboard, shredder, etc.). Protecting personal data:  As soon as you begin a project, identify the personal data you will be dealing with as part of your work.  Protect the confidentiality of data in a manner commensurate with their sensitivity, including in case of dissemination of such data.  Where required by law, keep a register of data processing to detect risks and implement actions to remedy them.  Purge data from your personal storage media as soon as the data is no longer in use.

BE AWARE

Computers and data protection

 Follow Group guidelines and rules when you work at home or away in a mission. Protecting personal data:  Immediately inform your legal division, or data protection officer or correspondent if you suspect or know of data theft or loss (e.g. on a USB stick), or if data have been altered (e.g. hacking). STRICTLY FORBIDDEN  Disclosing information that is not classified as "public" concerning the activity of Groupe ADP and its subsidiaries, in any form, without legitimate reason and without applying appropriate protective measures.  Disclosing specific information on social media about projects you are working on or have worked on. Protecting personal data:  Communicate personal data to persons who are not among the identified recipients.  Keep personal data beyond the period defined in the register, in particular on a hard disk or other mobile support.  Reuse personal data for purposes other than those originally intended.

SAVING AND BACKUPS

3 UPDATES

PASSWORDS

Use complex passwords, avoid using the same password in several places, never reveal a password.

Only save your work data on the company’s storage media.

Apply any updates required by the IT department on to your devices as soon as possible.

4 FLASH DRIVES

5 EMAIL

6 DOWNLOADING

Avoid the use of flash drives / USB sticks and never use them to store confidential data (high risk of loss or malware propagation); use the sharing platform by existing company tool for file transfers.

Report all suspect messages to your IT department, and examine all links and attachments before clicking on them.

If in doubt, ask your IT department, to check download links for safety.

8 SEPARATING WORK/ PERSONAL USES Keep your work and personal uses separate, including email, devices, storage, etc.

7 ROAMING

9 MALWARE

Never store work data on your PC; always use the storage options provided by the company; use privacy filters on your computer screen.

Immediately turn off your workstation if it behaves oddly and contact IT support.

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

For example,

UPHOLDING THE PRINCIPLES OF FREE COMPETITION AND FIGHTING COLLUSIVE AND COERCIVE PRACTICES Open, unhindered competition is a basic requirement for healthy and loyal business relations. Competition law forbids price-fixing, contract-sharing, and strategic information sharing between competitors, as well the abuse of a dominant position. It requires that economic actors competing for the same contract be treated equally. In its relations with its business partners, Groupe ADP bases its behaviour on the principles of loyalty, transparency and non-discrimination. In purchasing, Groupe ADP applies very specific rules that regulate public contracts. Ignorance or lack of understanding of these rules exposes employees and the company to heavy penalties.

During a conference, a colleague from another airport told me that he would like to share airport best practices with me. As this seemed useful to me, we decided to exchange information by e-mail every month.

Exchanges of commercially sensitive information, i.e. non-public, current or future, individual and non-aggregated information relating to business confidentiality, are prohibited and may be sanctioned. This information concerns, in particular, pricing and cost strategies

Is this acceptable ?

and commercial policy with regard to airlines.

Consulting the Legal Department will help you decide what is and is not possible.

THE PROS Fair and equitable competition in our business relationships guarantees the confidence of all our stakeholders.

It is an essential element for the success and sustainable growth of the Group, and guarantees its reputation.

COMPETITION LAW SANCTIONS FRANCE AND EUROPE

For the company • Up to 10% of its consolidated worldwide sales

For personally liable employees • For the most serious cases, up to 4 years imprisonment • 75,000 euros fine

• Nullity of the agreement or of the disputed clauses • Action for damages • Exclusion from tendering procedures • Loss of reputation

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

COLLUSION

PENALTIES EXCLUSION

Collusion refers to practices (agreements, associations, etc.) between economic actors aimed at distorting or even preventing free competition in the procedure for awarding a public contract. The objective of all these practices is to enable a predetermined candidate to win a contract.

EUROPEAN UNION • Collusion between economic operators is prohibited by EU law. Candidates who engage in collusive practices may be excluded from tendering procedures between EU member states. Such practices can also lead to legal proceedings.

WORLD BANK GROUP • The exclusions prohibit the supplier from contracting with any World Bank Group (WBG) institution, any organization whose activities are funded and advised by the WBG. These exclusions

Groupe ADP pays particular attention to fighting collusive practices.

may be accompanied by financial penalties.

BEST PRACTICES

STRICLY FORBIDDEN  Exchange, directly or indirectly, strategic information with competing airport operators.  Facilitate, directly or indirectly, the communication of commercially sensitive information between competing customers, business operators or suppliers.  Participate in meetings with the client during the bidding period outside of any organized and validated hearing process for all candidates.  Providing bids for services of convenience to win a contract.  Holding regular informal meetings with authority officials during a bidding process.  Agreeing among candidates on the content of bids in advance (e.g., price, geographic distribution of contracts, etc.).

For example,

 Act fairly with our partners (suppliers, customers, businesses, etc.) by providing the same information to each.  In case of doubt about the practices of a partner or competitor, consult your manager, the Legal Department or the Ethics and Compliance Officer in order to assess the risks that may exist and determine the appropriate course of action.  Comply with the good practices presented in the note "Beware of collusive practices in the context of calls for tenders".

A local government organized a tender for the construction of a new runway. ADP Group applied for the contract. An employee made an agreement with one of the other candidates that the winner would choose the other company as subcontractor. We were awarded the contract. Can we subcontract half of the work to the candidate with whom the employee has reached an agreement?

No , since the two bidders had previously agreed, this is a prohibited collusive practice.

BE AWARE  Report any suspicion of unfair competition or collusive practices to your manager.

For example,

Our consultant was involved in informal discussions about bid prices with the local authority that is leading a bidding process for an airport concession. Can our company be sanctioned as a result of these discussions?

 Give rebates, discounts and financial advantages in any form whatsoever without following the proper procedures.

Yes , it can be considered that the final price of the ADP Group's offer depended on the discussions that the consultant had with this authority. This is a collusive practice contributing to unfair competition.

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

FOCUS ON COERCIVE PRACTICE

FOCUS ON FAVORITISM

In France, there is a specific offence of favoritism in the context of public procurement. It is constituted by the simple fact of "procuring or attempting to procure for others an unjustified advantage by an act contrary to the legislative or regulatory provisions designed to guarantee freedom of access and equality of candidates in contracts and concessions". Penalty: In France, it is punishable by two years of imprisonment and a fine of €200,000.

A coercive practice consists of influencing the actions of a person or legal entity by harming or threatening to harm them or their property.

Sanction: These practices can be sanctioned by European or international institutions.

For example,

In the context of an airport project, the procurement of two World Bank-funded terminals was found to involve intimidation of competing candidates. Company A, even before the bidding, made threats against the future business interests of the competing companies and the safety of their employees. Later, Company A's representatives held a competitor's employees captive to force the competitor to miss the bidding deadline.

An employee sends a supplier A a quote from another supplier B to see if they can match the price.

No, this prevents competition and favors supplier A who, by proposing a lower estimate, is certain to obtain the order. This is an offence of favouritism.

Is this acceptable?

BEST PRACTICES  Strictly respect the rules of public procurement: equality between candidates, freedom of access and transparency of procedures.  Put all purchases out to tender in accordance with the Group's procedures.  Call on the Purchasing Department for all purchases, regardless of the amount.  Provide a precise and objective description of needs when making a purchase.

BE AWARE  In case of non strictly professional relations with suppliers, not to take part in the procedure (in particular not to judge the applications and offers).  Refrain from transmitting to the outgoing incumbent any information on the current call for tenders other than that transmitted to all candidates.  To be objective in the description of the requirements and the analysis of the offers (any judgment must be traced in the offers submitted).  Rejecting a candidate's offer without giving any reasons even though he was the best bidder.  Favouring a candidate by providing him with information to facilitate the preparation of his offer.  Orienting its needs so that only one candidate is able to respond to the competition.

This is coercive and a serious breach of free competition. It reduces the development impact of the project and damages confidence in the Bank's procurement system. They must be denounced in order to be sanctioned.

Is this acceptable?

STRICLY FORBIDEN

 Accepting an invitation/gift offered by a supplier, candidate to a call for tender.  Concluding a rider allowing the execution of services not provided for in the initial contract (including extension of the duration) outside the cases provided for by the public order code.

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