Universal Registration Document 2024

4 SUSTAINABILITY REPORT

MERGER OF THE SUSTAINABILITY REPORT AND THE VIGILANCE PLAN – KEY POINTS

Vigilance Plan – Framework and key points

The information published under the Vigilance Plan, identified by the "CP" pictogram, is not subject to external verification by the Statutory Auditors. Hughes Hubbard & Reed LLP assisted the Group in merging the Sustainability Report and the Vigilance Plan and issued the following statement: “As part of this exercise to consolidate the due diligence plan and the Sustainability Report required by EU Directive 2022/2464 on the publication of sustainability information by companies ("CSRD"), we supported Groupe ADP from the very first stages, by analysing the legal and operational feasibility of such a merger. Our presentation then focused on the points of convergence between the requirements relating to the Vigilance Plan (Law 2017-399 of 27 March 2017) and those arising from the CSRD. In analysing the legal aspects of the Vigilance Plan and its integration into the sustainability report, we focused on the consistency and transparency of the information. This work underlines the importance ADP places on a rigorous and strategic approach to maximising the transparency and harmonisation of its regulatory obligations. Nicolas Tollet – Partner Hughes Hubbard & Reed LLP

The Act of 27 March 2017, known as the "Potier law", imposes a duty of vigilance on parent companies and order givers whose registered office is in France and employ more than 5,000 people, including subsidiaries. Groupe ADP meets these criteria and must therefore implement a Vigilance Plan that includes reasonable measures to identify risks and prevent serious violations of Human Rights, fundamental freedoms, the health and safety of individuals and the environment. These risks and harm may result from the Group's activities, those of its subcontractors or suppliers with whom it has an established commercial relationship. Groupe ADP's Vigilance Plan is based on the following pillars: 1. risk mapping: identifying and assessing potential risks; 2. regular assessment procedures: ongoing analysis of the situation of subsidiaries, subcontractors and suppliers in relation to risk mapping; 3. mitigation and prevention actions: implementation of appropriate measures to reduce risks or prevent serious harm; 4. whistleblowing and reporting systems: system for signalling the existence or occurrence of risks; 5. monitoring and evaluation system: monitoring of actions implemented and assessment of their effectiveness. The Vigilance Plan is published and is updated each year.

For the past three years, Groupe ADP has published a standalone document, separate from its management report, to make it easier to understand and be more transparent about the way in which it fulfils its duty of vigilance. With the convergence of regulatory requirements in terms of non-financial reporting (CSRD and duty of vigilance), Groupe ADP has chosen to review the terms of its non financial communication. The aim is to strengthen the overall consistency of its reporting, while simplifying and clarifying the Group's commitments and actions for all its stakeholders, in support of its sustainability and duty of vigilance. The double materiality assessment carried out in 2024, in accordance with the CSRD recommendations, identified the material issues on which Groupe ADP must communicate in its Sustainability Report (see section 1 General disclosures – Part 1.4 IRO analysis of this document). The key issues identified under the duty of vigilance correspond in whole or in part to the stakeholders and material issues covered in the Sustainability Report. For this reason, Groupe ADP has chosen to address, whenever possible, the major issues (material and/or duty of vigilance) specific to the same stakeholders in the same place in the report. The structure of the Sustainability Report, which is more constrained than that of the Vigilance Plan, thus serves as the primary reference. An initial simplified cross-reference table below provides a quick overview of the common and distinct issues between Sustainability and Duty of Vigilance (entry key: Sustainability Report), and a second cross-reference table at the end of the report provides a more detailed overview of the answers to the specific requirements of the Vigilance Plan (entry key: Vigilance Plan).

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