Code de conduite Anglais 2023

CODE OF CONDUCT GROUPE ADP

CODE OF CONDUCT GROUPE ADP

PÉRIMÈTRE GROUPE ADP

V2 – 07/2023

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

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