Universal Registration Document 2024

SUSTAINABILITY REPORT 4 GOVERNANCE MATTERS

Annual communication plan To promote ethical issues, the annual communication plan includes publicising the challenges of the programme via different channels (website, extranet, intranet, emails, etc.). The intranet site and website (https://www.parisaeroport.fr/ groupe/rse/ethics-and-compliance) and extranet (for Groupe ADP subsidiaries – https:// connexions.groupe - adp.com/ethics-compliance) contain a section dedicated to the Ethics and Compliance Programme. In 2024, 52 communication actions were carried out (compared with 23 in 2023 1 ) to strengthen the ethics and compliance culture, including the mapping of corruption risks, World Bank monitoring, management of employee and executive commitments, collusion, and “Chairman's fraud” scams.

It comprises 16 representatives of the Group with different expertise and two qualified external persons (a philosopher and a former Ethics Director of a large company and director of an NGO that is prominent on integrity issues). The ethical responsibility of corporates is expanding to include the environment, the prevention of climate change, respect for Human Rights, the prevention of psychosocial risks and new ways of organising work within the company. In 2024, the Ethics Committee met twice to discuss: u best practice from other companies in the use of Artificial Intelligence (AI); u the revision of the first AI questionnaire defined to assess the impact of projects deployed within the Group.

NUMBER OF ETHICAL COMMUNICATIONS ACTIONS IN 2024: 52

A “Speak up” culture 2 Groupe ADP organised an ethics day accessible to all Group employees dedicated to the prevention of corruption in 2021 and 2022. The exercise was extended in 2023 to include ethics issues, with three round tables: the whistleblowing system, the perception of ethics and the Ethics Climate Barometer. Due to operational constraints, the next ethics day has been rescheduled to April 2025. The aim of this day is to increase employees' confidence in a global system and, in particular, to develop confidence in and awareness of the whistleblowing system, so that breaches of ethics and compliance can be reported and dealt with internally. Another major challenge is to ensure that ethics and compliance is taken into account in business relationships. A manager kit has been set up to enable managers to discuss these issues with their teams. It consists of processed

reports that have been anonymised for the exercise. This dialogue and training enable the teams to prepare for all sensitive situations by developing collective and situational intelligence. To bring this kit to life, it was decided to include situations in the Horizon Managers training aimed at getting managers to think about the company's culture. Ethics Climate Barometer Thanks to the Ethics Climate Barometer conducted each year, all employees are invited to respond and more than 3,000 (sample analysed by a polling institute to ensure representativeness) report their understanding of ethics and compliance issues and the level of reputation and trust in the whistleblowing system, while comparing themselves to employees of large companies. The barometer enables the Group to guide awareness-raising to ensure a homogeneous ethics and compliance culture.

1 2023 communications on ethics day, Ethics Climate Barometer, training, values and corporate purpose, code of conduct, compliance plan, whistleblowing charter, etc. 2 “A "Speak up culture" is a work environment where employees feel comfortable speaking their minds, sharing their ideas and expressing their concerns without fear of negative consequences. In other words, it is a place where all employees feel safe to express themselves when they have something to say; no matter what it is.” (Definition by Hannah West, Speak Up culture – what is it and why is it important?) (goodcourse.co).

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UNIVERSAL REGISTRATION DOCUMENT 2024 w AÉROPORTS DE PARIS