Euronext - 2020 Universal Registration Document

Risk Management & Control Structure 2 Control Structure

through policies and training and themonitoring of those policies and by providing a path for communication for employees. Compliance with applicable rules and principles and ethics is key to Euronext’s success and it is the obligation of every employee to support this effort. Euronext’s code of business conduct and Ethics sets and reaffirms Euronext’s high standards of ethical conduct and reinforces its business ethics, policies and procedures. Compliance with the Code is required of all board members (Managing Board, Supervisory Board and any other board) and all employees including consultants, contractors and temporary employees. The Code of Business Conduct and Ethics, which is supplemented by nine corporate compliance policies, governs without exception all business activities of the Company. The code of business conduct and Ethics is available on the Euronext website. The availability of the Code of Business Conduct and Ethics as well as the compliance policies at all times, in local languages on the Company intranet, in addition to general training and awareness sessions and communication targeting all Company employees as well as targeted training for employees in sensitive roles that require additional awareness and training determine the effectiveness of the Code. The Code of Business Conduct and Ethics is also supported by an external confidential reporting system that enables employees to report, in an anonymized manner should they choose, alleged breaches of a general, operational and financial nature. Relevant policy and procedures ensure that reporters in good faith are free to do so without fear of retaliation in accordance with the laws in the countries where Euronext operates. The Company protects anyone who reports an alleged breach of laws or Company policies in good faith and ensures that they shall in no way be put at a disadvantage by the Company as a result of the report. Guidelines and procedures are defined notably to ensure that antimoney laundering and sanctions, bribery and fraud and conflicts of interest concerns are managed and that business is always conducted in a fair manner. The Code of Business Conducted is linked to other internal compliance policies covering money laundering and sanctions, gifts meals and entertaining and prevention of bribery, persona trading and the prevention of fraud are maintained by the Compliance department (for a complete list of internal compliance policies please refer to section 3.7 of this Universal Registration Document). Staff training and awareness sessions are conducted regularly in all Company locations to promote compliance and ethics standards. Finally, given the dual positions of Euronext as amarket operator and a listed issuer on the Euronext markets, the Compliance department has imposed strict personal dealing rules and a conflicts of interest procedure to ensure that neither the staff nor the Company itself could take undue benefits from this situation. Compliance processes are established as follows:

for Standardization (ISO) and the Business Continuity Institute (BCI). Euronext’s Crisis Management framework includes escalation and communications rules, guidelines for action, and clearly defined roles and responsibilities. In 2020, in addition to regular training, testing and exercises, work was undertaken to help improve, mature and embed Business Continuity at Euronext. In 2020 the BCM plans were tested by the outbreak of the Covid-19 pandemic. Furthermore, the BCM program continued to mature through maturing crisis management plans. Program Development – Euronext continues to drive improvements to its risk management process and the quality of risk information generation, while at the same time maintaining a simple and practical approach. The roadmap for 2019-2020 for the ERM evolution included three key elements: n embedding culture of risk management: Risk appetite discussions with the first line, key risk indicator discussions, ongoing training at various levels of the organization; n involvement in key initiatives related to Oslo integration, strategic acquisitions; n reporting/operation: ongoing risk appetite evolution, enhanced management reporting, risk tool maturity, further alignment of risk management and internal control approach for addressing risk and identifying controls. The 2021–2022 roadmap will continue with the topics above and training program maturity and ongoing integration of new acquisitions. Euronext seeks to continuously evaluate and improve the operating effectiveness of the ERM process. 2.3.1.2 Internal Control Euronext has established a strong framework of internal control across its business areas and functions. This framework is based on ethical principles, established procedures and training of the key personnel who are responsible for implementing and overseeing it. The internal control function as a second line of defence, aims at ensuring, in a permanent manner that identified risks are mitigated by controls, that controls are effective, documented and reported and that internal procedures exist and are updated on a regular basis. Euronext is strongly committed to conducting its business with integrity, excellence and responsibility and to adhering to high standards of ethical conduct. Euronext’s culture promotes accountability and responsibility and an open culture of dialogue and is bolstered by the corporate Compliance department. The role of Corporate Compliance is to establish and maintain a first class compliance culture within the Company and to ensure that Euronext’s business approach is in line with the highest ethical standards. The Compliance department supports Euronext and its employees in complying with applicable laws and regulations and promotes ethical standards in accordance with good Corporate Governance. The Compliance department raises awareness among employees by articulating the responsibilities of the Company and its employees 2.3.1.3 Corporate Compliance – Code of Conduct and Ethics

Risk mitigation thought policies and procedures

Staff training and awareness

Monitoring of policies and procedures

Dialogue with businesses

More information on Euronext’s commitment to Ethics are provided in Chapter 3 of this Universal Registration Document

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2020 UNIVERSAL REGISTRATION DOCUMENT