Universal Registration Document 2024

4 SUSTAINABILITY REPORT GOVERNANCE MATTERS

[G1-1-10-(b)] → No anti-corruption or bribery policy consistent with the United Nations Convention against Corruption is in place Not applicable – Groupe ADP already has an Anti-Corruption Programme. [G1-1-10-(b)] → Timetable for the implementation of anti-corruption or bribery policies in line with the United Nations Convention against Corruption Not applicable – Groupe ADP already has an Anti-Corruption Programme. [G1-1-10-(c)] → Disclosure of guarantees relating to the notification of irregularities, including the protection of whistleblowers The Director of Ethics and Personal Data is responsible for handling reports and works directly under the Group's Chairman and Chief Executive Officer to ensure the independence of this process. Once the admissibility of a report has been validated, it must be processed as quickly as possible, with the support of a processing committee to ensure that decisions are taken collectively (investigation strategy and post-investigation recommendations). The committee may then initiate a verification, investigation or audit. The handling of reports and the internal investigation process are initially governed by a charter. To ensure that whistleblower protection and confidentiality are properly taken into account in the whistleblowing process, Groupe ADP had its charter revised by Transparency International in 2018. The charter is available to all Group employees on the whistleblowing platform and in nine languages. In 2024, it was updated to: u reinforce the confidentiality inherent in the handling of reports; u ensure compliance with the Waserman law (protection of whistleblowers); u strengthen the process for handling reports that may concern a supplier or subcontractor in application of the duty of vigilance, with the complexity of handling a report at a co-contractor or within its own value chain. An in-house investigation team is dedicated, trained and subject to strict confidentiality rules as part of their contract. Its work is based on a charter for handling reports, an

investigator's guide and internal procedures that define a methodology and guarantee confidential, objective, impartial and proportionate handling. Throughout this process, the identity of the whistleblower is preserved. Acts of retaliation against this person may be punished. No sanctions have ever been imposed in this area. The strategy for internal investigations (proportionality of measures, people to be interviewed, ensuring that the case is made both for and against the accused, checking for conflicts of interest, outsourcing the investigation if necessary, etc.) is validated by a processing committee, whose members depend on the type of report and are subject to the same confidentiality rules. It validates the strategy, conclusions and recommendations on a collegiate basis. Protection measures are studied on a case-by-case basis and adapted to the allegations. The whistleblower's identity remains protected even after processing has been completed. The whistleblower is invited to contact the Ethics Department if he or she observes any retaliation after the fact. Feedback is organised after the surveys to update any reference documents. The processing charter was updated in 2020, in particular to take account of the publication of Directive EU2019/1937 on the protection of persons who report breaches of Union law, known as the “Whistleblowers Directive”, which came into force on 16 December 2019, and to anticipate transposition by the Waserman law in July 2021. It was last updated in 2024 for the reasons detailed in the previous point. [G1-1-10-(d)] → Timetable for implementation of policies on the protection of whistleblowers Not applicable – Groupe ADP has already implemented a processing procedure that includes the protection of whistle-blowers. [G1-1-10-(e)] → The company has procedures to investigate business conduct incidents promptly, independently and objectively The criteria for the admissibility of reports, as set out in current regulations, are specified in the relevant charter. At the same time, the Ethics and Data Department has formalised an admissibility grid to objectively document each case of non-admissibility.

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