ADP // 2021 Universal Registration Document

R I SK AND MANAGEMENT 2 RISK FACTORS

In addition, changes in these regulations or potential sanctions could increase the costs of compliance. 5 – B: Groupe ADP is subject to particularly stringent civil aviation security standards, non-compliance with which could have a negative impact on its business as an airport operator. The safety of civil aviation is a priority for the air transport industry. Safety standards are established at a global level under the aegis of the International Civil Aviation Organization (ICAO). These measures include the standards and practices recommended by the ICAO and which the signatory states of the Chicago Convention of 7 December 1944 have undertaken to implement. They are not directly applicable and are only ascribed a regulatory value when they are transposed into the states’ national laws. For airports situated in the European Union, the applicable legal framework is set by European Community law and by the rules of the European Aviation Safety Agency (EASA), which reflect the ICAO’s recommended standards and practices. On this basis, the European Airport Security Certificate can be granted in accordance with the provisions of Regulation (EC) No. 216/2008 of the European Parliament and of the Council of 20 February 2018. For airports situated in countries outside the European Union, Groupe ADP is subject to the current local certification processes. Violation of these standards is likely to jeopardize the safety of air transport, prevent the operation of airports and the group could be held liable. In addition, these standards could be strengthened, making Groupe ADP responsible for fulfilling additional obligations.

Under French Law No. 2017-399 of 27 March 2017 on the duty of care of parent companies and contractors (the Potier Law), the Groupe ADP is also required to deploy a due diligence plan to identify and prevent or mitigate, for its entire value chain - including its main suppliers and subcontractors, the risks of serious violations of human rights and fundamental freedoms, the health and safety of individuals, and the environment. In the event of failure to implement a due diligence plan, the Group may be challenged by any third party with an interest in the matter, and then ordered by a court to comply with the law, and in the event of damage caused as a result of failure to comply with these obligations, be required to pay compensation for the loss suffered. These laws include a training system and a whistleblower protection system that exposes the Groupe ADP to possible civil, criminal or disciplinary proceedings. In France in particular, the French Anti-Corruption Agency can monitor the implementation of the eight compliance points provided for in the Sapin 2 law, including the evaluation of third parties. A draft European directive on the duty of care also provides for the establishment of an administrative authority to control and sanction similar to this agency. In addition, many institutions issue guidelines to which states are subject (European Union, United Nations, World Bank, etc.) that may apply to the group. For example, certain subsidiaries of the World Bank may be partners in certain projects. Although the Groupe ADP has implemented an ethics and compliance program to ensure that its practices comply with regulatory texts, failure to comply in any way with these regulations and the Group’s principles could result in legal action being taken against the Groupe ADP and could adversely affect its development, results and reputation.

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AÉROPORTS DE PAR I S / UN I VERSAL REG I STRAT I ON DOCUMENT 202 1