Euronext - 2020 Universal Registration Document

Euronext, a Sustainable Exchange 3 ESG Risks Considerations

3.5 ESG Risks Considerations

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 several initiatives in place to employee wellness (please refer to section 3.7 “Encourage health and safety at work”) in addition to upholding European labor laws. Given Euronext’s geographic footprint (primarily Europe) and sector. 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 upholding labor laws in the jurisdictions in which it operates. Euronext has confirmed its support for the Ten Principles of the United Nations Global Compact, and supports the UN Guiding Principles on Business and Human Rights, and the International Labor Organization conventions and recommendations. Euronext complies with these fundamental rights, conventions and recommendations, notably on social rights, freedom of association and equality and, abolishment of forced and child labor. Euronext employees benefit from local works councils in Denmark, France, the Netherlands, Norway and Portugal. Given Euronext’s geographic footprint (primarily Europe) and sector. Euronext employees are covered by national and 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. Euronext operates in an industry where the risk of modern slavery and human trafficking is inherently low and in jurisdictions where labour standards are high. However, Euronext operates as an international business and recognizes the risks of partnering with a varied spectrum of global suppliers comes with a responsibility as such 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. In 2020, the supplier code of conduct was reviewed to reinforce ESG considerations for all Euronext suppliers. 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. Euronext seeks to reduce its environmental footprint where possible. In 2019, Euronext partnered with Carbone 4 in order to clearly identify and assess its potential climate-related risks and opportunities in addition to calculating its carbon footprint.

As mentioned in Section 2 – Risk Management and Control Structure, Euronext assess the materiality of ESG and related risks. Euronext recognizes the importance of ESG issues notably those of the environment, human rights, antibribery and corruption risks. They are not currently considered principal risks for the Group, and these risks where they are relevant are identified under risk categories within the Group risk taxonomy. The below discussion seeks to clarify areas in which Euronext analyses ESG risk 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 a market infrastructure and an issuer, further controls and policies in order to ensure the highest standards and integrity are maintained: n Code of Business Conduct and Ethics; n Euronext Personal Trading Policy; n Policy Preventing Insider Trading on Euronext N.V. Financial Instruments; 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 Whistleblower 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 (see section 3.4.4.1 – Act ethically, with integrity and the highest standards in terms of good governance) .

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2020 UNIVERSAL REGISTRATION DOCUMENT