Aéroport de Paris - 2018 Registration document

SOCIAL, ENVIRONMENTAL AND SOCIETAL RESPONSIBILITY INFORMATION 17 AÉROPORTS DE PARIS CORPORATE SOCIAL RESPONSIBILITY (CSR) POLICY

THE LIFE CYCLE APPROACH AND AN ENERGY PERFORMANCE CRITERION INCLUDED IN PURCHASES An internal CSR-environment purchasing procedure was also deployed in 2018 to integrate the life cycle approach into the purchasing process, in accordance with the requirements of the 2015 version of ISO 14001. This approach takes environmental impacts into account at each stage of the life cycle for the different purchasing categories. Moreover, the Purchasing Department and the Environment, CSR and Regions Department have targeted the purchasing families most at risk through their impact on energy consumption, and raised awareness of specifiers and buyers so as to include a specific energy performance criterion. A guide to identifying relevant criteria for “high energy- consumer” segments has been introduced. For these segments, the energy performance criterion is included in consultations during offer rating, and is separate from the CSR criterion. WHISTLE-BLOWING MECHANISM Groupe ADP has deployed a whistle-blowing platform accessible by suppliers to meet the requirements of the Sapin 2 law. It also includes a hotline for people without access to internet. Human rights As a member of the UN Global Compact since 2003, and with Advanced Level status since 2015, Groupe ADP undertakes to comply notably with the Universal Declaration of Human Rights in all its activities. In its sustainable development goals, it has selected SDG 4: “ensure inclusive and equitable quality education and promote lifelong learning opportunities for all” and SDG 5: “achieve gender equality and empower all women and girls”. In 2015, Groupe ADP also signed the Mobilisation Charter to fight for equality against racism, supported by the Human Rights Defender. Our TAV subsidiary has been a member of the UN Global Compact since 2015 with the GC Active level. Fight against corruption In 2018, Aéroports de Paris SA deployed an Ethics and Compliance action plan validated by the Executive Committee, the Board of Directors and its Audit and Risk Committee. Committed to basing its development on principles which reflect its ethical commitment, Groupe ADP formalised its ethics rules at the end of 2016 in a Responsible Lobbying Charter, available on its website. Since 2017, it is also registered in the list of interest representatives held by the High Authority for Transparency in Public Life (Haute Autorité pour la transparence de la vie publique) in accordance with the Sapin II law. In 2017, Transparency International designated TAV Airport as the more effective company in terms of anti-corruption, transparency and reporting measures in Turkey. Ethics and compliance: the seven pillars of the action plan The Ethics and compliance action plan includes the fight against corruption. It is based on seven pillars: ◆ management exemplarity: In 2018, all the members of the Executive Committee (including ADP International) made a written commitment to deploy the Ethics and Compliance Action plan in their scopes of responsibility. These written commitments were duplicated for the TAV Airport, AIG, ADP Ingénierie and Hub One subsidiaries. In addition, via a letter sent to the top management, the Group’s Chairman and Chief Executive Officer launched the Gifts and Invitations procedure; ◆ the risk mapping: the Ethics and Compliance risk was considered significant for the Group given its international exposure. The Ethics Department, with the Security and Risk Management Department,

launched work to reinforce training in the third party and corruption risk mapping in 2019; ◆ dedicated governance: the Ethics Department was created in 2018. Its Director reports to the Chairman and Chief Executive Officer, thus guaranteeing the Department’s independence in processing alerts. The Ethics Department defines and steers the Ethics and compliance action plan with the Legal; and ◆ Insurance Department. To extend the plan to the Group’s subsidiaries, these departments are supported by the Ethics & Compliance contacts in ADP International, ADP Ingénierie, TAV Airport, AIG and Hub One, as well as the Ethics and Compliance relays appointed in Aéroports de Paris’ departments. The programme is monitored in the Group’s different bodies: Executive Committee, Works Committee, Board of Directors (and its Audit and Risk Committee); ◆ definition and diffusion of policies, rules and methods: ◆ included in the internal rules of procedure, Aéroports de Paris SA’s code of ethics was distributed, via the intranet and internet sites, in the form of a communication document entitled “Group Ethics code of conduct and compliance”. It includes best practices, areas of vigilance and prohibitions as well as examples of tangible cases. At the start of 2019, it will be distributed in person to Aéroports de Paris SA’s employees. The French subsidiaries have their own code of conduct. For the international scope, a code of conduct translated into seven languages was distributed within the subsidiaries, ◆ at Group level, the Embargos, Gifts and invitations and Conflicts of interest procedures were distributed for the first time. This corpus will be reinforced in 2019, ◆ in 2018, the 13 procedures defined for the international scope, dealing notably with third party assessment, payment facilitation, embargo policy, etc. were introduced within the international subsidiaries controlled by the Group; ◆ whistle-blowing mechanism: Accessible since 1 October 2018 to Group and supplier employees, the alert platform (https://report. whistleb.com/fr/adp) meets the requirements of the Potier law (duty of vigilance) and Sapin 2 law (fight against corruption). Integrated into the platform, a charter manages the admissibility criteria for alerts and defines the protection for whistle blowers. It was subject to an audit by Transparency International. The platform’s accessibility and the protection of whistle blowers were promoted by a Group communication in France and to the TAV, AIG, ADP Ingénierie and Hub One subsidiaries; ◆ training and awareness raising: An intranet and an internet site (parisaeroport.fr/groupe/groupe-strategie/ethique-et-compliance) dedicated to the Ethics and compliance action plan were launched in December 2018. An e-learning programme is currently being produced. This will include several modules dealing as a priority with ethics and compliance issues, the fight against corruption, conflicts of interest, gifts and invitations; ◆ monitoring of the Ethics and compliance mechanism: An ethics climate barometer was produced for the first time in 2018 to measure employee perception on ethics, and specifically conflicts of interest and corruption. It is also used to measure the level of awareness and confidence in the alert system. Furthermore, Aéroports de Paris is a member of Transparency International and also of the “Cercle Éthique des Affaires” which helped Groupe ADP to promote Ethics to its employees. Mapping of suppliers at risk in terms of ethics and corruption As part of the approach steered by the Group Ethics Officer, Aéroports de Paris SA’s Purchasing Department has defined a methodology to assess risks of corruption in the area of purchasing both prior to the contract signing and during the contract execution, in accordance with the law.

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AÉROPORTS DE PARIS ® REGISTRATION DOCUMENT 2018