ADP // 2021 Universal Registration Document

SOC I AL , ENV I RONMENTAL AND SOC I ETAL RESPONS I B I L I TY I NFORMAT I ON 4 OPERATING IN AN EXEMPLARY MANNER

2021 achievements and results The main achievements on these seven pillars are: ◆ more than 29,000 customers and suppliers assessed; ◆ risk mapping: Groupe ADP monitored the action plans resulting from the 2020 mapping; ◆ between the end of 2018 and 2021, the Group processed 43 admissible alerts resulting in 19 investigations, 16 recommendations and seven sanctions; ◆ control: the third ethics climate barometer was carried out in 2021. The fight against tax fraud Present in several dozen countries, Groupe ADP deploys its tax policy according to three main principles: ◆ prevalence of the business activity; Its policy is based on OECD standards, which aim, on the one hand, to locate and tax revenue in the country where the business is carried out, taking into account the functions performed, the risks assumed and the assets used, and on the other hand, to improve transparency and the level of information on transfer prices, notably via Country-by-Country Reporting (CBCR) to eliminate all tax evasion situations. As a matter of principle, the Group rejects investments in tax havens and countries, states and territories considered to be non cooperative on tax matters (ETNC), unless these investments are justified by active business and/or trade (e.g. an airport) other than tax savings. ◆ fair taxation of operations; ◆ management of tax risks. The law of 27 March 2017 creates a duty of vigilance for parent companies and order providers with regard to their subsidiaries, as well as sub-contractors and suppliers, in order to protect against serious violations of human rights and fundamental freedoms, and the health and safety of people and the environment. Subsidiaries and companies controlled within the meaning of article L. 233-16 of the French Commercial Code are concerned, as are the leading service providers with which the Group has a long-term business relationship and for which social, environmental and ethics risk mappings covering corruption have been drawn up. All Group employees and suppliers may use the whistle-blowing mechanism deployed in 2018 for ethics and compliance (see the whistle-blowing mechanism in the chapter “Ethics and Compliance Programme”). In addition to the information provided below, Groupe ADP will publish a dedicated vigilance plan in the first half of 2022. The vigilance plan Policy and objectives

TRAINING AND AWARENESS-RAISING An intranet site and website (https://www.parisaeroport.fr/en/ group/csr/ethics-and-compliance) are dedicated to the Ethics and Compliance action plan and on-site training and e-learning sessions are regularly held to raise employee awareness. In 2019, the Group rolled out a mandatory e-learning course which was taken by more than 10,000 employees. After 2020 and 2021, when many employees were on partial employment, a reminder was sent out at the end of 2021 to have 100% of employees trained by the end of 2022. In addition, 700 employees exposed to ethics and compliance risks received face-to-face training. In 2021, the heads of assets 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. New specific modules will be rolled out in 2022 to continue training for exposed populations. All Group employees within the scope subject to the GDPR (EU) are made aware of the protection of personal data. An e-learning course has been deployed for all employees and persons 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. MONITORING OF THE ETHICS AND COMPLIANCE MECHANISM Thanks to the ethics climate barometer conducted each year, more than 3,000 employees report their understanding of ethics and compliance issues and the level of reputation and trust in the whistle-blowing 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. 2021 survey figures ◆ 81% believe that their managers act ethically (+12 points vs employees of large companies); ◆ 75% of employees are aware of the whistle-blowing system (+11 points vs employees of large companies) and 64% trust the whistle-blowing system (+5% vs. employees of large companies). The ethics and compliance controls included in the Group’s internal control framework have been reviewed and tested in the field. In terms of data protection, control is organised into three levels (business line, data protection team and Audit Department). The GDPR compliance management platform and documentation (AIPD) make it possible to monitor action plans by processing or by department. The data protection team performs self assessments as part of internal control. ADP SA monitors the compliance of Group entities through Group committees (two to three times a year).

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