Every employee should be proactive in preventing fraudulent behaviour.

• Enforce all applicable instructions and procedures;

• Protect the company’s assets and inventory (facilities, equipment, etc.);

• Track all actions and retain all supporting documents.

• In cases of suspected fraud, be sure to inform your manager, the Legal Affairs Division, or the Group’s Ethics & Compliance officer.

• Agreeing to ignore the company’s procedures.

• Carry out daily operations with openness, equity and honesty, and in compliance with Groupe ADP's standard operating procedures;

• Let our partners know about our commitment to fight corruption;

• In cases of suspected or attempted corruption, inform your manager or the Group’s Ethics & Compliance officer;

• Refer to the Responsible Lobbying charter which provides guidance on the representation of interests.

• Feeling indebted after having received some advantage or benefit from a partner;

• Dealing with intermediaries (or business ‘introducers’) without communicating our commitments against corruption or enshrining them contractually;

• Accepting or offering a gift or hospitality without analysing the context.

• Offering or accepting bribes, gifts, hospitalities, services etc. in order to obtain a call for tenders or in exchange for confidential company information;

• Agreeing to use an intermediary specified by a client or prospect in order to secure a contract;

• Approving receipt of a service or order greater than what was actually provided/ delivered in order to obtain a benefit from the provider, either for oneself or for others;

• Considering a business relationship (see procedure on third party assessment) without first checking up on the third party in question (suppliers, customers, etc.);

• Making facilitation payments in order to ease or speed up obtaining authorisations.

THE SINGLE EXCEPTION TO THESE PRINCIPLES:
a margin of tolerance applies when a person’s physical safety- or his or her relatives - is threatened. If this should happen, you should immediately inform your manager, HR manager, the Legal Affairs Division or the Ethics & Compliance Officer.

• Analyse the context in which gifts or hospitalities are offered or accepted, using the 4 criteria presented below;

• Give preference to advertising gifts or to those whose value is purely symbolic;

• During professional gatherings, Groupe ADP may fund transport and lodgings if it is useful and beneficial for business;

• Always ask your manager for approval for all gifts/hospitalities whose value is > € 200*.

• Avoid all gifts or hospitalities that might lead an outside observer to question the integrity of the giver or the recipient;

• Avoid all gifts or hospitalities that might affect the impartiality of any decisions an employee must make in the interests of Groupe ADP.

• Accepting: any amount of money, even as a loan or a guarantee, or the free provision of moveable assets or property, equipment, trips or other service provided by a third party, either for oneself or for one's family, friends, or colleagues;

• Accepting any kind of gift or hospitality that places you in the giver’s debt in any way;

• Accepting any gift or hospitality during a strategically-important time (e.g. a call for tenders).

• Carry out your duties at work in the sole and strict interests of the company, and never based on personal interest;

• Know how to spot a potential or emerging conflict of interests;

• Report any actual or suspected conflict of interests to your manager or Ethics & Compliance officer, and decide together on the best way to deal with the situation in order to minimise the risk to the employee and the company.

• Be aware of your friends, family, or employees who might have business or personal relations or even financial interests with a Groupe ADP supplier, competitor, or customer;

• In some public situations (e.g. elected mandate), be sure to avoid taking part in decisions relating to Groupe ADP, its subsidiaries or its joint ventures.

• Concealing a conflict of interests that could be damaging to the Group or an employee;

• Maintain the highest levels of discretion and confidentiality when dealing with company- related data, whether inside or outside the company;

• Assess the confidentiality of the information contained in a given document and record its level on that document, using the Group's 4-tier confidentiality scale (public, restricted, confidential, highly confidential). See also the Group’s data protection policy*;

• Make sure your surroundings are secure when working on confidential information, using only company equipment and never doing such work in public places;

• When communicating CONFIDENTIAL or HIGHLY CONFIDENTIAL information (whether verbally, in writing, or digitally), make sure you are communicating only with known and identified persons; if such persons are not part of Groupe ADP or if the data is HIGHLY CONFIDENTIAL, make sure you obtain a confidentiality agreement;

• Store and destroy the documents you deal with based on their confidentiality level (reinforced cupboard, shredder, etc.).

Protecting personal data:

• As soon as you begin a project, identify the personal data you will be dealing with as part of your work;

• Follow the local regulation and internal rules about data protection (record, collect...);

• Your data protection actions should be proportional to the level of confidentiality of the data, including in cases of transmission;

• Purge data from your personal storage media as soon as the data is no longer in use.

• Follow Group guidelines and rules when you work at home;

• Follow Group regulations when away on mission.

Protecting personal data:

• Immediately inform your legal division, or data protection officer, or your IT if you suspect or know of data theft or loss (e.g. on a USB stick), or if data have been altered (e.g. hacking).

• Disclosing information, documents or files of any kind, including current or planned projects or studies, in particular industrial, commercial, financial, technical or other operations, or any secrets and processes relating to the business of any Groupe ADP company, in any form, without legitimate reason and without applying appropriate protective measures;

• Disclosing specific information on social media about projects you are working on or have worked on.

Protecting personal data:

• Not respecting the terms of local regulation or internal rules about personal data protection.

• Always treat our partners fairly (suppliers, customers, businesses, etc.) by providing every stakeholder with the same information.

• Report to your manager if you suspect prohibited collusion between competitors (e.g. bidders in a call for tenders who decide to engage in price fixing);

• Never offer rebates, discounts or financial benefits of any kind without following the proper procedure;

• When in doubt, consult with your manager, the Legal Affairs Division, or your Ethics & Compliance officer in order to assess any potential risk and decide how to move forward.

• Directly or indirectly disclosing strategic information to competing airports;

• Directly or indirectly facilitating the disclosure of confidential business information between competing customers, trade operators or suppliers.

• Being attentive to our employees and colleagues and treating them fairly;

• Creating an environment that fosters trust and dialogue in order to better manage sensitive issues within our teams. For example: encourage direct discussion rather than emails as soon as possible, write clear and courteous emails, limit the amount of email sent outside work hours except in emergencies;

• Be respectful: treat work colleagues, partners and customers in a way that is consistent with the Group's major commitments;

• Inform your manager or Ethics & Compliance officer in cases of harassment or discrimination;

• Inform our partners of the broad lines of our ethical commitments and be ready to discuss these issues with them.

• Keep an eye out for hints and indications that colleagues may be in an uncomfortable situation;

• Detect and escalate any instances when our partners deviate from our ethical principles.

• Direct or indirect discrimination, particularly during the hiring or promotion process;

• Acting in ways which might be experienced as harassment or sexist behaviour.