Euronext - 2019 Universal Registration Document

Euronext, a sustainable exchange 3

Euronext’s Five ESG Impact Areas and the Sustainable Development Goals

Furthermore, Euronext maintains a strong focus on detecting integrity breaches such as market abuse, market manipulation, and insider trading which are reported to regulators. Euronext has internal procedures and dedicated teams for this purpose and to ensure compliance with requirements of the Regulation (EU) No 596/2014 of the European Parliament and of the Council of 16 April 2014 on Market Abuse (“Market Abuse Regulation”). Prevention of market abuse by Euronext staff is supported by a Personal Trading Policy, a Euronext N.V. Insider trading Policy as well as a Confidential and Inside information Policy. Finally, Euronext has adopted an anti-bribery policy and a conflict of interest policy according to best practice to comply with local laws, as well as a gift meals and entertainment policy which strives to ensure all Euronext staff upholds the highest standards with respect to conflicts of interest and anti-corruption. Those polices covers all business and all operations of Company. The Anti-Bribery Policy is established to prevent, identify and report the activities constituting bribery in its many forms. The Policy encompasses all forms of corruption and bribery including attempt or appearance of corruption. Similarly, Euronext has established the Conflicts of interest Policy to avoid conflicts situations, ensure that Employees understand what a conflict of interest is, in its many forms and offer guidance to Employees on how to manage such conflicts. The Policy encompasses all business and operation of the Company with a dedicated focus for certain highly regulated businesses. The aforementioned policies apply to Euronext and its majority owned subsidiaries, and to all Euronext employees including consultants (including interns and temporary staff) and agents. They are available to Company employees on the Intranet and employees are required to participate mandatory trainings. Training and awareness Staff training and awareness sessions are conducted regularly in all company locations to promote compliance and ethics standards. Each new employee is trained shortly after joining by the Euronext Compliance department. Euronext conducts ongoing training as refresher and as necessary, such as following the modification of these policies. In 2019, all Company employees were required to complete an anti-corruption training. In 2020, they will be required to Complete a conflicts of interest training that will be available on a dedicated eLearning platform Finally, some teams receive specific training as they have been identified as more exposed to certain risks.

The enterprise risk management framework also illustrates Euronext’s commitment to ESG. Euronext governance includes an internal audit department, supported by external firms to audit specific items, providing an independent and objective assurance on the organisation’s governance, risk management and internal control. In 2019, eleven (11) assignments on various domains, including Information Technology, Business entities and Support functions, have been conducted. Euronext Code of Business Conduct and Ethics Euronext has adopted a Code of Business Conduct and Ethics that reaffirms its commitment to high standards of ethical conduct and reinforces its business integrity, policies and procedures. The Code of Business Conduct and Ethics explains the Company’s core values and basic ethical obligations in conducting business. In particular, it addresses the following themes: n conflicts of interest;

n inside information and personal trading; n confidential information and privacy; n anti-money laundering, sanctions; n anti-bribery;

n data protection n fair competition.

Euronext Compliance Policies These policies aim at ensuring compliance with the laws and promoting best practice as well as the higher ethical standards. They intend to raise awareness among Euronext employees and avoid non-compliance or reputational risks. Euronext has implemented the Anti-Money Laundering and Sanctions Policy and Guidance according to the 4 th European Union AML Directive. The financial sector relies on Euronext to act as a gatekeeper preventing money laundering and terrorist financing activities. The Euronext Anti-Money Laundering and Sanctions Policy is designed to ensure compliance with EU AML Directives and Regulations applicable to an operator of regulated markets and trading venues. It includes the need to have in place appropriate systems and controls to identify and mitigate the risk of Euronext being used to facilitate money laundering, other financial crime and terrorist financing.

2019

2018

Number of staff that received the training

303

208

Percentage of total employees

90.1%

88.90%

90

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2019 UNIVERSAL REGISTRATION DOCUMENT