Universal Registration Document 2024

SUSTAINABILITY REPORT 4 GOVERNANCE MATTERS

4.4.2.1 Taking account of ethics and compliance issues in corporate governance [G1-ESRS 2 GOV-1] Role of administrative, management and supervisory bodies in preventing ethics and compliance risks (including corruption)

At TAV and AIG, the heads of Ethics and Compliance also meet regularly with their Chairman and Chief Executive Officer. The Ethics and Compliance programme is monitored by the Executive Committee, the Social and Economic Committee and the Board of Directors (Audit and Risks Committee and CSR Committee). Each month, Ethics and Compliance issues are also discussed at an Executive Committee meeting. The Board of Directors' ESG Committee reviews actions relating to the dissemination of the ethics and compliance culture, especially the results of the Ethics Climate Barometer.

[G1-ESRS 2 GOV-1-5-(b)] → Disclosure of the role of the administrative, management and supervisory bodies in business conduct matters The Ethics and Personal Data Director reports functionally to the Audit, Security and Risk Management Department, and hierarchically to the Chairman and Chief Executive Officer with regard to the independent handling of alerts. She reports to the Chairman and Chief Executive Officer on a monthly basis. The Ethics and Personal Data department defines and co-pilots the Ethics and Compliance action plan with the Legal and Insurance departments, and holds weekly meetings to identify common issues to be addressed.

Executive Committee 03/06/2024 13/05/2024 03/06/2024 23/09/2024 03/12/2024

Board CSR Committee 09/06/2024 04/10/2024 04/10/2024

Board Audit and Risk Committee

Board of Directors 21/06/2024 16/10/2024 16/10/2024 16/10/2024 18/12/2024

Ethics Climate Barometer

Vigilance Plan

09/10/2024 09/10/2024 09/10/2024 09/12/2024

Human Rights commitments

Corruption mapping

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Annual review of the Ethics and Compliance Programme (including Personal Data Protection review)

Groupe ADP has set up a governance structure dedicated to Ethics and Compliance commitments: The Ethics department was created in 2018. In 2021, it expanded its scope by integrating the teams responsible for personal data, coordination of the Vigilance Plan and the Human Rights dimension. It became the Ethics and Personal Data Department in 2021, incorporating the challenges of personal data protection. In 2023, it revised its organisation into five divisions to meet the new challenges and extended scope of deployment: u deployment of the programme and management of ethics and compliance controls; u personal data protection; u duty of vigilance and Human Rights; u project risk prevention and third party assessment; u survey and dissemination of the ethics and compliance culture.

The departments rely on the Ethics and Compliance officers within the subsidiaries to implement the Ethics and Compliance programme. To ensure the proximity of the approach, 26 officers located in controlled subsidiaries and their subsidiaries, i.e. , one for every 1,000 employees or so, promote the ethics and compliance culture and monitor the implementation of the standards with the teams concerned. In addition to these contacts, 20 coordinators (network of "Internal control, Audit, Risks and Ethics" or CARE) are appointed within the support departments at the level of the parent company to promote the various Ethics and Compliance practices and thus prevent the related risks. This network also contributes to the implementation of best practices covering aspects such as the reporting of gifts and invitations and conflicts of interest every year.

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UNIVERSAL REGISTRATION DOCUMENT 2024 w AÉROPORTS DE PARIS

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