Aéroport de Paris - 2018 Registration document

RISK MANAGEMENT AND CONTROL 04 RISK FACTORS

Risks related to ethics and compliance – Extra-financial risk

RISK IDENTIFICATION

RISK MONITORING AND MANAGEMENT

The implementation of Groupe ADP’s ethics and compliance programme is managed by the Ethics Department, which was created in 2018, together with the Legal and Insurance Department. These two departments are supported by “ethics and compliance” contacts to implement the programme within the Group’s main subsidiaries. This programme is based on the following seven pillars: ® management setting an example; ® mapping risks related to ethics and compliance and to the duty of vigilance; ® programme monitoring at a Group and subsidiary level bodies; ® the definition and implementation of policies, rules and methods, the sharing of engagements with the stake holders (ex: signature of the ADP SA CSR charter by the suppliers); ® the whistle-blowing mechanism in the form of a platform accessible to all of the Group’s employees and those of its suppliers; ® training, awareness-raising and information for all of the Group’s employees, particularly through the forthcoming introduction of an e-learning programme; ® monitoring of the ethics and compliance mechanism, particularly by establishing the first ethics climate barometer. The goals, policies and achievements of this extra-financial risk are described in the “Governance and ethics” paragraph of the “Social, environmental and societal responsibility information” chapter. In support of the ERA 2016-2020, the “Connect 2020” strategic plan establishes the goals of Groupe ADP for the period 2016- 2020. The Finance, Management and Strategy Division guarantees that the ERA is fulfilled and is consistent with the strategic plan. It carries out the Group’s strategic and financial control, structured around road maps. Moreover, Aéroports de Paris annually consults airlines on the topics of service quality, investment programme and pricing proposals during economic consultative commissions. For the 2019-2020 annual pricing, the ASI did not approved the first pricing proposal made by Aéroports de Paris (increase of 2.944% for the three airports). Aéroports de Paris made a second pricing proposal, which increase by +1.00% the tariff for Paris-Charles de Gaulle and Paris Orly airports, and by +3.52% for Paris-Le Bourget airport. This second proposal was approved by the ASI. See chapter 6 – point related to the evolution of fee levels for the 2019-2020 annual pricing. RISK MONITORING AND MANAGEMENT

In view of the expectations regarding ethics and compliance (the Sapin II and Potier laws, existing standards, etc.), there is a double challenge for Groupe ADP: ® deploy an Ethics and Compliance culture at all levels; ® reinforce the ethics and compliance programme in order to meet standards, and particularly international standards.

Risks related to economic regulation

RISK IDENTIFICATION

The missions of Aéroports de Paris fall within the scope of the Economic Regulation Agreement (ERA), in line with articles L. 6325-2 of the French Transport Code and R.224-4 of the French Civil Aviation Code. The ERA 2016-2020 was signed with the government authorities on 31 August 2015. The airport fee cap takes into account cost, revenue and investment projections, as well as quality of service targets. The regulation allows for the airport operator to receive fair compensation on capital invested within the regulated scope, assessed based on the weighted average cost of its capital. However no assurance can be given as to the level of fees that Government authorities will authorise it to apply after 2020. In addition, in circumstances upsetting the economics of the contract, the ERA could be revised or even cancelled early. Moreover, the Independent Supervisory Authority for Airport Fees (ASI) is in charge, in line with article R. 224-7 of the French Civil Aviation Code, of the approval of the annual pricing for airport charges made by Aéroports de Paris. Even with the application of an Economic Regulation Agreement (ERA) which set the conditions of the pricing for airport charges, and despite the French Civil Aviation Code articles, the ASI shall be subject to challenge the elements which are included within the annual airport charges proposal, under the control of an administrative judge. Finally, both the pricing and approval decision can lead to an action for annulment before the administrative judge.

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AÉROPORTS DE PARIS ® REGISTRATION DOCUMENT 2018