Universal Registration Document 2024

SUSTAINABILITY REPORT 4 GOVERNANCE MATTERS

[G1-3-20] → Information on how policies are communicated to those for whom they are relevant (prevention and detection of corruption) See the ethics culture programme detailed above. [G1-3-21-(a)] → Information on the nature, scope and depth of anti-corruption or anti-bribery training programmes offered or required See [G1-3-AR 8] below → Prevention and detection of corruption – anti-corruption training table. [G1-3-21-(b)] → Percentage of functions-at-risk covered by training programmes 100% of employees at risk are covered by the training plan; it is revised each time a corruption risk mapping exercise is carried out, each time a new entity is integrated and as often as necessary (see G1-1-10(h), G1-3-18(a) and G1-3-AR7). [G1-3-21-(c)] → Information on anti-corruption and anti - bribery training given to members of administrative, supervisory and management bodies See [G1-ESRS 2 GOV-1-5-(b)] → Disclosure of the expertise of the administrative, management and supervisory bodies on business conduct matters.

[G1-3-AR 7] → Analysis of the company’s training activities, for example by region of training or by category The training plan, validated in August 2024, details the way in which the Group deploys its training and awareness programmes within ADP SA and its subsidiaries. In 2024, 25 entities (subsidiaries and controlled companies) in 10 different countries identified exposed employees (see details below). [G1-3-AR 8] → Prevention and detection of corruption – summary table of training on anti-corruption and bribery Groupe ADP's training plan lists the categories and functions of people exposed to the risk of corruption. It draws up a correspondence table indicating the appropriate training. All people working in an exposed position must follow Module 1 – General Ethics and Compliance, and depending on their scope: u Module 2 – Relationships with suppliers, customers and intermediaries; u Module 3 – Relationships with the authorities, politics and non-profits; u Module 4 – Free competition.

Relationships with the authorities, politics and non profits

Relationships with suppliers, customers and intermediaries

Ethics and Compliance

Free competition

Personal Data Protection

Group

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Purchasing Sponsoring Legal Affairs Development

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Finance

Asset

Operations

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Projects

Governance

Customers/commercial

Real Estate

Human Resources Communication

Accounting

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Ethics and Compliance Coordinator Ethics and Compliance Officer

User ADIT * marketer

User ADIT * other

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Executive Committee

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Members of the Management Committee

TOP 100

* Third party evaluation tool.

[G1-4] Incidents of corruption or bribery

2024

Number of convictions for breaches of anti-corruption and anti-bribery laws Amount of fines for breaches of anti-corruption and anti-bribery laws

0 0

507

UNIVERSAL REGISTRATION DOCUMENT 2024 w AÉROPORTS DE PARIS