Euronext - 2019 Universal Registration Document

Euronext, a sustainable exchange 3 ESG Risks Considerations

3.3 ESG Risks Considerations

several initiatives in place to employee wellness (please refer to section 2.5.3.4. “Encourage health and safety at work”) in addition to upholding European labor laws. Euronext employees benefit from local works councils in France, the Netherlands, and Portugal. Given Euronext’s geographic footprint (primarily Europe) and sector, Euronext does not face material Labor/Human Rights risks. Euronext employees are covered by European Labor Laws and the Company benefits from having Euronext has limited employees outside of Europe (US, India and Hong Kong) and is obligated to uphold European Labor Laws. At the end of December 2018 Euronext completed its acquisition of Commcise which at the time had staff in London and Bangalore. Post-acquisition a labour law consultant was engaged to work out a transition a plan to bridge any legal or regulatory gaps. Following the analysis and subsequent actions, Commcise is in line with the local labour laws that are applicable to both the service they offer and the industry. Euronext seeks to ensure the highest standards within the Company and throughout our supply chain via the Euronext Supplier code of conduct. This code of conduct first signed in 2015 includes provisions regarding human rights, diversity and inclusion, and environmental protection, ensuring that Euronext has an ethical supply chain. Additionally all new vendors are screened for past or current sanctions. For further information regarding our supply chain please refer to section 3.4.2. Environmental As an electronic services provider, Euronext does not directly engage in materially environmentally sensitive activities. Nevertheless, Euronext is committed to environmental sustainability and has endeavoured over the past 10 years to offer an increasing range of ESG products and services to its clients. In 2019, Euronext partneredwith Carbone 4 in order to clearly identify and assess its potential climate-related risks and opportunities in addition to calculating its carbon footprint. Climate change will have a material impact on the global and regional economy in which Euronext is a key player. While these changes will have economic and social consequences, thepreliminary assessment conducted with Carbone 4 has concluded that Euronext’s carbon footprint is relatively low and the exposure to climate change related risks are limited. However, Euronext believes that environmental challenges including climate change are relevant and will become increasingly so and has therefore included ESG in its strategic plan “Let’s Grow Together” as well as seeking to embed ESG within each of its strategic pillars. In line with its strategic plan Euronext will seek to further reduce its carbon emissions notably by analysing the environmental impact of its third party providers, and its technology usage by trying to promote IT solutions that reduce consumption of natural resources, for example the use of communication tools over international travel, reducing the footprint of physical platforms to virtual environments and reduction of hardware consumption.

As mention in Chapter 2 Risk Management and Control Structure, Euronext as a European market operator does not face standalone material ESG risks. However ESG considerations are important to Euronext and certain risks faced by Euronext may be qualified as ESG are already taken into account in other risk categories. The below discussion seeks to clarify areas in which Euronext analyses ESG potential. Social Given Euronext’s role as market operator and mission to uphold the highest standards for a transparent market, the integrity of our markets is one of our imperatives. We believe that financial markets are a cornerstone to a well-functioning economy and, by extension, society. Therefore the risk of an integrity breach of our markets may be considered a societal risk. However, given the strict legal framework and highly regulated environment in which Euronext operates, these risks are considered as compliance risks. Euronext mitigates potential risks to our market integrity by ensuring strong controls and procedures. Euronext has implemented the Anti- Money Laundering and Sanctions Policy and Guidance according to the 4 th European Union AML Directive. Euronext maintains Member and Issuer Compliance teams to support fair and orderly markets and protect against integrity breaches such as market abuse, market manipulation and insider trading, which if detected are reported to Regulators. With respect to Euronext as an issuer, further controls and policies in order to ensure the highest standards and integrity are maintained: n Euronext Personal Trading Policy; n Euronext N.V. Insider Trading Policy; n Confidential and Insider Information Policy; n Conflicts of Interest Policy; n Anti-Fraud Policy; n Anti-Bribery Policy (in best practice accordance to local laws);

n Anti-Money Laundering and Sanctions Policy; n Gifts, Meals, and Business Entertainment Policy; n Employee code of conduct; n Whistleblowing policy.

Euronext ensures regular training sessions for all employees and targeted training sessions for those employees with access to potential price sensitive information. Euronext also manages a whistleblowing policy to ensure employees have a place to report issues confidentially. For further information please refer to the section 3.7. Euronext employees are essential to the Company and are a critical stakeholder. While Euronext protects itself from key man risk through succession planning and its organization (please refer to section 2.3.7. for further information) employee health, wellbeing, and growth are imperative to the Company. As such Euronext has

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2019 UNIVERSAL REGISTRATION DOCUMENT