Euronext - 2020 Universal Registration Document

Euronext, a Sustainable Exchange

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

Good Corporate Governance The Company respects the Corporate Governance Guidelines, Recommendations and Codes set in place in the Netherlands (see section 4.1), and aims to comply with the ones set in place in the other Euronext locations, and notably the French Afep- Medef Recommendations and the 2020 Belgian Code on Corporate Governance. The governance of Euronext reflects the highest standards of independence, oversight, and transparency. The Company applies strict principles and guidelines to its own governance practice and to the companies that list on its markets. More figures related to the activities of the Managing and the Supervisory Boards may be found in section 3.6 – ESG Dashboard . 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; 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 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 or terrorist financing. 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. n inside information and personal trading; n confidential information and privacy; n antimoney laundering, sanctions; n antibribery; n data protection; n fair competition.

Finally, Euronext has adopted an antibribery 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 cover all business and all operations of Company. The Anti-Bribery Policy is established to create a framework to prevent, identify and report the activities constituting bribery in its many forms. The Policy encompasses various 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 and consultants (including interns and temporary staff) and agents. They are available to Company employees on the Intranet and employees are required to participate in mandatory trainings. For more information on the Code of Business Conduct and Ethics see section 2.3.1.3 – Corporate Compliance – Code of Business Conduct and Ethics Whistleblowing Program The Company, via its Whistleblowing Policy and Procedure, allows Employees and third parties to report in confidence alleged breaches of the laws or Company policies, and protects anyone who reports in good faith, ensuring that they shall in no way be put at a disadvantage by the Company as a result of the report. The policy provides internal and external mechanisms to report unlawful and unethical behaviors. The internal mechanism allows employees to report alleged breaches either to the Compliance department or directly to the management or to the Chairman of the Supervisory Board under specific circumstances, in which cases they must necessarily inform the Compliance department of the report received. The external mechanism is managed by the Compliance department per internet by a specialized provider and allows employees anonymous reporting. The Company is committed to protect reporting employees against retaliation. The Whistleblowing Policy and Procedure also describe how the reports are treated, how investigations are carried out including confidentiality aspects as sets for in the laws and contains the rights and obligations of Employees when they want to report an alleged breach. The Company has also upgraded its Policy and Procedure to ensure compliance with laws of the jurisdictions where it operates. The Compliance department maintains a log of all reported alleged breaches, tracking their receipt, investigation and resolution and on an annual basis reports a summary to the Company’s Audit Committee, as described in the Whistleblowing Policy. The Whistleblowing Policy is available on Euronext Website (1) and on Euronext Intranet in the main languages used in the Company. Employees participate in mandatory trainings mostly through e-learning platform and are informed on the mechanisms to report unlawful and unethical acts and behaviors.

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(1) https://www.euronext.com/fr/node/721.

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2020 UNIVERSAL REGISTRATION DOCUMENT