Universal Registration Document 2024

SUSTAINABILITY REPORT 4 GOVERNANCE MATTERS

4.4.2.5. Raising awareness and training on ethics and compliance issues [G1-1-10-(g)] → Information on the company's business conduct training policy Training and awareness-raising

Since 2019, the Group has rolled out a mandatory e-learning course which has been taken by more than 10,000 employees. The rate of completion of this general module by employees is: u 94% for the 2025 Pioneers strategic roadmap; u the company also has a specific objective in the calculation of the profit-sharing paid each year to the employees of Aéroports de Paris SA: 95% in 2024

In 2024, the ethics training plan was strengthened with a document describing how it will be implemented, including: u target populations; u training content and awareness-raising in-person or through e-learning; u the methodology for identifying staff at risk for Group employees, adjusted in line with the mapping of corruption risks.

In-person training and awareness raising sessions continued in 2024. Since 2018, more than 250 interventions within Groupe ADP populations (management committee, networks, ethics and compliance tool users, etc.) have been carried out on various topics, such as: u the Ethics and Compliance programme; u third-party assessment; u data protection; u duty of vigilance/Human Rights; u a manager kit containing cases processed and anonymised as part of the whistleblowing system has been formalised to enable the Group’s main managers to lead sessions and practice how to deal with sensitive situations. One of Groupe ADP's major challenges is to integrate its new subsidiaries into its ethics and compliance system. To this end, the Ethics and Personal Data Department regularly works with the Entity Manager community to familiarise them with new issues and procedures. In 2021, the heads of entities within the operations department were trained in order to strengthen their ability

to challenge the subsidiaries on their ethics and compliance programme within the bodies in which they represent Groupe ADP. In 2022, the Group's expatriates were made aware of their role as ambassadors in their missions within international entities. Group employees within the scope subject to the GDPR (EU) are made aware of the protection of personal data. In 2024, a new e-learning programme was rolled out for all employees. People in key data protection positions are invited to in-person training on the requirements of the GDPR, which they must comply with, and/or for which they must ensure application in their daily activities. As part of the partnerships with EDH ( Entreprises et Droit de l’Homme ) and RHSF ( Ressources Humaines Sans Frontières ), specific training in Human Rights has for the moment been offered gradually and on a voluntary basis to duty of vigilance (ethics, purchasing, internal control, audit, legal, employment law and HR), then to Entity Managers. As part of the action plan, awareness-raising and training courses on Human Rights will be rolled out on a larger scale in 2025 and 2026, according to the type of personnel involved (general public, experts, exposed populations).

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UNIVERSAL REGISTRATION DOCUMENT 2024 w AÉROPORTS DE PARIS