Aéroports de Paris SA

Reference: page 219

The Board of Directors is the body responsible for monitoring impacts, risks and opportunities, assisted by the Audit and Risks Committee. The Board comprises 17 non-executive members and 1 executive member, including six employee directors elected on 24 May 2024 for a five-year term. Women represent 38.89% and men 61.11% of directors, and 23.53% of Board members are independent. The Board examines opportunities and risks, including financial, legal, operational, social and environmental risks, in light of the strategy it has set. Management keeps regular tabs on the follow-up of identified impacts, risks and opportunities, supported by a second line of control covering internal control and risk management. Targets for material matters are set by the Executive Committee and, where appropriate, by the Board of Directors, with many stemming from the 2025 Pioneers strategic roadmap launched in 2022. Director skills and expertise, including on sustainability, are set out in the Corporate Governance Report, and each director may receive training on the Company and its sustainability challenges.

Reference: page 221

As part of preparing the Sustainability Report, several Groupe ADP bodies were consulted: the Audit and Risk Committee (ARC), the CSR Committee, and joint ARC-CSR committees to pool the bodies involved in this cross-functional issue. For each committee, a presentation and written information were provided to members, with the sequence of passages through these committees set out in the IRO-1 section on the double materiality assessment. On social and environmental responsibility, the Board of Directors takes into consideration social and environmental challenges and the Company's corporate purpose when determining strategic orientations, in line with the Board's internal regulations. The international development strategy is based on a CSR assessment benchmark inherent to the Group's value offer. The materiality assessment, its methodology and results were presented to the various governance bodies, with the presentations detailed in the IRO-1 disclosure on the decision-making process and related internal control procedures.

Reference: page 221

Incentive schemes linked to sustainability exist for the Chairman and Chief Executive Officer and are based on the variable portion of remuneration, using quantitative and qualitative criteria including sustainability objectives. CSR objectives covering environmental and social issues carry a 25% weighting in the variable component of the Chairman and Chief Executive Officer's remuneration. The targets, focusing in particular on climate and social objectives, are defined by the Board of Directors both for setting objectives and for measuring their achievement, and are detailed in the Corporate Governance Report. Outcome metrics used for the objectives form part of the indicators in the corresponding sustainability areas, for example the work accident frequency rate. The Board of Directors, acting on a recommendation from the Compensation, Appointments and Governance Committee, sets the objectives and measures their achievement, subject to approval by the Annual General Meeting both ex ante and ex post. Non-executive corporate officers receive only fixed fees per meeting based on attendance.

Reference: page 223

Groupe ADP discloses a mapping of where information on its due diligence process appears in the sustainability statement, structured around the core elements of due diligence. Integrating duty of vigilance and sustainability into governance, strategy and business model maps to GOV-1, GOV-2, GOV-3 and IRO-1. Identifying and assessing adverse impacts, including risk mapping and regular assessment of subsidiaries, subcontractors and suppliers, maps to IRO-1 and SBM-3. Stakeholder engagement, including whistleblowing and reporting systems, maps to SBM-2 and to the S1-2, S2-2, S3-2 and S4-2 engagement disclosures. Remediation of negative impacts maps to action plans such as E2-2, E4-3, S1-4, S2-4, S3-4 and S4-4. Monitoring, covering the monitoring and evaluation of actions and their effectiveness, maps to the MDR-T disclosures in the topical ESRS. The mapping reflects the merger of the Sustainability Report and the Vigilance Plan, with references to the Vigilance Plan framework and key points provided for each phase.

Reference: page 222

The risk management and internal control system used for the Sustainability Report is aligned with the Group's overall approach to controlling its activities. Groupe ADP's risk management system qualifies and assesses all types of risk, including CSR risk, within operations and across the value chain, and the Audit, Security and Risk Management department adapted existing processes for CSRD. To assess risks inherent in preparing the report, Groupe ADP set up a CSRD project team including representatives from all departments. Internal control covers the first (business line) and second (independent controls) lines, with controls carried out by the data producer at level 1, the internal control or consolidation unit at level 2, and the Audit department at level 3. In 2024 the second line focused on awareness-raising and ensuring first-level controls were carried out, and used double materiality findings to target metrics needing closest attention. Internal control and the Group Risk Manager take part in monthly CSRD Task Forces, and the internal control system was presented at a joint CSR-Audit and Risk Committee meeting at the end of October 2024.

Reference: page 224

Groupe ADP is a major player in the management, operation and development of airports worldwide. Its 2025 Pioneers strategic roadmap defines priority transformation actions for 2022-2025 across three areas, with the associated 2025 Pioneers for Trust ESG strategy covering environment, territories, employer and governance. Main products and services span airport services, commercial and passenger services, and real estate development. Main customers are airlines, passengers and end users, and office tenants. In 2024 the Group reported a headcount of 29,330 employees and total revenue of 6,158 million euros, split across Aviation (2,054), Retail and Services (1,930), Real Estate (332) and International and Airport Developments (1,971). The Group is active in the fossil fuels sector through fuel oil purchase and resale in Almaty and natural gas purchases by Paris airports, generating revenue of about 320 million euros in 2024. It has no banned products, no controversial weapons activity and no tobacco activity. The Group has identified a contribution to 11 of the 17 UN Sustainable Development Goals.

Reference: page 226

Taking account of stakeholders' expectations is central to Groupe ADP's strategy, building on initiatives that predate the CSRD, including the Maison de l'Environnement at Paris-Charles de Gaulle created in 1995 and the first materiality assessment in 2014. A Stakeholder Committee created in 2021, made up of 16 external experts, allows the Group to pick up warning signs and major CSR trends. The stakeholder map sets out seven categories, including customers, employees, public players, regional development players, directors and financiers, airport partners, and social influencers. The Planning, Sustainable Development and Public Affairs Department coordinates engagement in France, while each international subsidiary organises its own dialogue. Maisons de l'Environnement at Paris-Charles de Gaulle and Paris-Orly welcome over 30,000 people each year. Stakeholder feedback is analysed and may feed into action plans or modify strategy, and Stakeholder Committee results are presented annually to the Executive Committee and the Board's CSR Committee. The Paris 2024 Olympic and Paralympic Games shaped the strategy for welcoming people with disabilities.

Reference: page 231

Groupe ADP identified 18 material issues following its double materiality assessment, presented in a double materiality matrix. Six environmental matters are material: three linked to E1 (climate change mitigation, adaptation and new energy sources), two to E2 (air and water pollution), and one to E4 (biodiversity). Eleven social and societal matters are material: three under S1 (employee health and safety, securing skills and making jobs attractive, social dialogue), two under S2 (value chain worker health and safety, securing value chain skills), three under S3 (reducing noise pollution, quality of dialogue with local stakeholders, economic development), and three under S4 (public and airport safety and security, hospitality for all, access to multimodal hubs). One governance matter under G1 is material (prevention of ethics and compliance risks, including corruption). The disclosure describes material impacts, risks and opportunities by issue, their time horizons, and how Groupe ADP responds through the Pioneers for Trust roadmap. As 2024 is the first year of CSRD reporting, anticipated financial effects and prior-period comparisons are stated as not applicable.

Reference: page 229

Groupe ADP carried out its double materiality assessment in three stages. During 2023 it questioned French stakeholders via an online questionnaire, asking them to rank 21 CSR sustainability issues by importance and performance, receiving over 1,000 responses supplemented by qualitative interviews with experts and stakeholders. In 2024 it produced a double materiality assessment on the scope of controlled subsidiaries. Taking the CSRD list of 89 sustainability issues as a reference, issues specific to Groupe ADP were added, and each issue was rated in the second quarter of 2024 for impact materiality and financial materiality. IROs were rated across the entire value chain, modelled as three value chains: Airports, Real Estate, and Retail and Services. The Audit, Safety and Risk Management department adapted the existing risk rating scale, applying a probability scale, a financial risk extent scale, and a triple impact scale covering scale, scope and irremediability. The validation process was referred to the ARC, CSR Committee, Executive Committee and Board of Directors across 2023 and 2024. This being the first year of CSRD reporting, prior-period comparison is not applicable.

Reference: page 240

For this first Sustainability Report, Groupe ADP complied with European legislation under the CSRD and with duty of vigilance legislation. A cross-reference table specifies the disclosure requirements complied with following the materiality assessment, listing the ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1, SBM-2, SBM-3, IRO-1 and IRO-2) together with the topical standards assessed as material: E1, E2, E4, S1, S2, S3, S4 and G1, with page references for each disclosure requirement. ESRS E3 (water and marine resources) and E5 (resource use and circular economy) were not retained as material. The explanation that climate change is not material for E1 is stated as not applicable, since E1 was split into three material topics analysed in detail later in the report. Policies relating to material issues have been adopted and are specified in the topical ESRSs, with timetables for policies and action plans set out in each thematic ESRS.

Reference: page 283

Groupe ADP has drawn up transition plans for seven hubs out of the 15 in the consolidated scope, representing 72.7% of the Group's GHG emissions, noting that calculation methodologies may differ between hubs. These plans are not yet consolidated into a single Group transition plan, but the consolidated hubs share the Pioneers for Trust climate change mitigation strategy and common decarbonisation levers. The sub-section sets out decarbonisation levers for Scopes 1 and 2 and for Scope 3, operating and capital expenditure, locked-in emissions and implementation progress. Scope 1 and 2 levers include improving the energy performance of installations through an energy efficiency plan, developing thermal renewable energy (deep geothermal, waste heat recovery, biomass heating, biogas), reducing the carbon footprint of the vehicle fleet, and purchasing Guarantees of Origin or Renewable Energy Certificates alongside developing photovoltaic solar power. Decarbonisation roadmaps have been defined for the Paris and AIG hubs using ACA certification years as a reference. For example, Paris-Charles de Gaulle has 33,968 tCO2eq to decarbonise by 2035 to reach Net Zero. Groupe ADP aims to have a consolidated Group-level transition plan by 2027.

Reference: page 253

Groupe ADP's double materiality assessment identified three material climate issues: adapting to climate change, climate change mitigation, and the development of new energy sources. To address these, the Group is progressively structuring and deploying several policies. The climate policy comprises a climate change mitigation plan aimed at controlling and reducing GHG emissions from air transport, and a climate change adaptation plan aimed at controlling the vulnerability of Group assets and activities to physical and transition climate risks. The energy policy rests on two axes, energy sobriety and energy transition, and supports the ambition to turn airports into energy hubs capable of distributing and producing low-carbon energy at scale. The environmental policy, named Airports for Trust, is integrated into the 2025 Pioneers for Trust CSR strategy within the overall 2025 Pioneers strategic policy. It integrates climate change mitigation, energy saving and the energy transition, together with commitments on resource efficiency and circularity and limiting pressure on biodiversity. Groupe ADP is committed to achieving net-zero emissions across its value chain by 2050, underpinned by monitoring and reduction of Scope 1, 2 and 3 emissions.

Reference: page 262

Groupe ADP is preparing a roadmap to advance climate change adaptation, with a detailed action plan for its Paris hubs planned for 2025 to identify and validate adaptation actions ensuring asset resilience. Physical and transition climate risks have been assessed in two stages: a 2022-2023 study of current and future gross risks at all Group airports across 2030 and 2050 horizons, identifying the most critical sites, followed by an in-depth net physical risk analysis begun at the end of 2023 for financially controlled airports. The net risk study uses site visits to account for existing and planned mitigation and adaptation actions, assesses the cost of additional measures, and evaluates the impact of net risk on asset value. It has been completed for the Paris airports and Amman Airport, with Izmir-Adnan Menderes and Milas-Bodrum visits planned for early 2025. Internally, a joint steering committee brings together the Sustainable Development Department and the Audit, Security and Risk Management Department. Adaptation has been presented to the Executive Committee in 2022, 2023 and 2024. In September 2024 the Group created an Environment Project Manager position for climate change adaptation. External engagement includes UNESCO, the World Economic Forum, EDF, SNCF and ACI Europe.

Reference: page 267

Aéroports de Paris SA's GHG emission reduction targets were certified by the SBTi (Science Based Targets initiative) in early September 2024 and made public in October 2024, confirming alignment with the Paris Agreement and a maximum 1.5C trajectory. The targets cover the Paris region hubs: Paris-Charles de Gaulle, Paris-Orly and Paris-Le Bourget. The validated commitment is a Net Zero commitment corresponding to a 90% absolute reduction in Scope 1, 2 and 3 GHG emissions by 2050 versus the 2019 reference year, with residual Scope 1 and 2 emissions offset by carbon capture projects. Medium-term targets are a 68% reduction in absolute Scope 1 and 2 emissions by 2030 and a 27.5% reduction in absolute Scope 3 emissions by 2030, both from the 2019 base year. On energy, Aéroports de Paris SA commits to source 100% renewable electricity annually through to 2030. Long-term targets include a 90% reduction in absolute Scope 1 and 2 emissions between 2035 and 2050 and a 90% reduction in Scope 3 by 2050. The six Kyoto Protocol greenhouse gases are taken into account, and Scope 1 and 2 long-term targets align with the airports' ACA targets.

Reference: page 274

Total energy consumption for Groupe ADP's controlled assets reached 1,073,390 MWh in 2024, up 10% from 976,328 MWh in 2023. Total fossil-based energy consumption was 595,390 MWh, up 15%, representing a 55% share of total consumption (53% in 2023). Within fossil sources, natural gas consumption was 354,936 MWh (down 3%), fuel from crude oil and petroleum products was 45,680 MWh (up 66%), and purchased electricity, heat, steam or cooling from fossil sources was 194,285 MWh (up 55%). There was no consumption from coal or nuclear sources. Total renewable energy consumption was 478,001 MWh, up 5%, representing a 45% share of total consumption (47% in 2023). This included 387,695 MWh of purchased renewable electricity, heat, steam and cooling, 54,197 MWh of renewable fuel, and 36,109 MWh of self-generated non-fuel renewable energy (up 18%). Energy intensity of operations in high climate impact sectors was 0.19 MWh per thousand euros of net income. Total energy consumption from activities in high climate impact sectors was 1,059,960 MWh, against net revenue from those activities of 5,460,238 thousand euros.

Reference: page 277

Groupe ADP's GHG statement was drawn up under the CSRD and the GHG Protocol. Scope 3 represents 99.3% of total CO2 emissions, dominated by Category 11 (use of sold products) at 21,515,245 tCO2eq. Total GHG emissions on a location-based methodology rose 1% to 22,819,107 tCO2eq in 2024.

The share of Scope 1 emissions from regulated emission trading schemes was 43% in 2024. No Scope 3 category is excluded. Total location-based GHG intensity was 3.71 tCO2eq per thousand euros of net revenue, based on 2024 consolidated net revenue of 6,158 million euros.

Reference: page 296

Groupe ADP is not currently absorbing or storing GHG through projects developed as part of its own operations or within its upstream or downstream value chain. In 2024 the Group entered a partnership with the Fondation de l'Universite Paris-Saclay to set up a research chair on carbon capture technologies applied to airports, with direct experimentation planned at Paris-Orly, covering both natural storage such as carbon sinks and technological storage such as carbon capture and storage. The Group voluntarily offsets emissions by purchasing carbon credits and financing projects outside its value chain, in particular to meet ACA levels 3+ and 4+ of the Airport Carbon Accreditation scheme, which cover residual Scope 1 and 2 emissions and employee business travel under Scope 3 Category 6. Holders include TAV's Ankara-Esenboga and Izmir-Adnan Menderes at level 3+, and Amman at level 4+, with Paris-Orly aiming for ACA 4+ by 2025. In 2023 the Group offset 16,264 tonnes of CO2, with a minimum of 14,475 tonnes offsetting Amman Airport. A service contract secures the purchase of carbon credits for the Paris hubs until 2030. Credits must be certified by Gold Standard, VCS, Label Bas Carbone, Climate Action Reserve or American Carbon Registry, and are used solely to complement direct emission reductions.

Reference: page 298

Groupe ADP applies an internal carbon pricing system within the investment project validation process, from the upstream feasibility and design phase, to encourage lower CO2 emissions during construction and operation. The Group uses two complementary schemes. First, a carbon shadow price, a company-defined carbon price incorporated into investment decisions and applied to the GHG emissions generated by projects in the operational phase, so as to favour the economic indicators of low-emission projects. The benchmark carbon price is mandatory for projects whose emissions fall under Scope 3 Category 2 and that have a direct impact on energy consumption and Scope 1 and 2 CO2 emissions, with CapEx above 3 million euros, and is applied only to the Paris region hubs. Second, a carbon budget for projects, setting a maximum volume of GHG emissions authorised over a complete cycle for all investment projects with CapEx above 5 million euros. The life cycle carbon budget comes into force from 2025 for Paris region hubs and TAV Airports, in line with KPI 3 of the 2025 Pioneers roadmap, and will then extend to AIG. To set its internal carbon price, the Group drew on sources including the Carbon Tracker Initiative, the Canfin-Grandjean-Mestrallet report and the Quinet commission report. In the test phase, 19 projects were assessed over 2022-2023, around 20% of Scope 3 Category 2 for Paris region hubs.

Reference: page 328

Groupe ADP covers both air pollution and water and soil pollution under E2, as it has no separate E3. The single environmental policy forms part of the 2025 Pioneers for Trust CSR policy and commits to move towards operations with zero environmental impact by first avoiding then reducing impact. On air, the policy is built on compliance with regulatory obligations and working with local authorities on an appropriate framework. The Group keeps a register of chemical products used at its Paris hubs, applies Best Available Techniques under the IED Directive, and operates an emergency procedure that shuts down production means when emission thresholds are exceeded. French discharges are governed by prefectural decrees. On water, mitigating water-pollution impacts is the primary concern, starting with strict regulatory compliance. A long-term water savings plan adopted by the Executive Committee in 2023 addresses water quality, reduction, substitution of drinking water with rainwater, restitution and improved discharge quality. The Group operates rainwater treatment and pollution retention basins at Paris-Orly, Paris-Charles de Gaulle and many foreign airports, uses biodegradable de-icing products, and stopped plant-protection products at Paris-Orly in 2015, Paris-Le Bourget in 2023 and Paris-Charles de Gaulle in 2024. Many hubs hold ISO 14001 certification.

Reference: page 330

For air, Groupe ADP applies dedicated measurement and engineering resources at each hub and the Best Available Techniques principle under the IED Directive. Ambient air quality at Paris-Charles de Gaulle and Paris-Orly is measured continuously, with readings every ten seconds averaged over 15 minutes, hourly, daily and annually. At each airport, two stations measure nitrogen oxides (NO, NO2, NOx) and suspended dust (PM10 and PM2.5) and one station measures ultrafine particles, with five air-quality stations in total across Orly, Paris-Charles de Gaulle and Paris-Le Bourget, accredited by COFRAC. The laboratory performs continuous self-monitoring against threshold values and publishes periodic reports. Foreign hubs apply emissions permits and periodic or continuous stack measurements, with a 24/7 station in Jordan measuring ozone, carbon monoxide, NOx, PM1 and PM2.5. For water, the Group maintains regular investment in collection, treatment and return systems. Paris-Charles de Gaulle invested several million euros in a multi-kilometre pipeline to discharge into the Marne, reducing flood and overflow risk, and operates a water control tower enabling live remote control of water flows by quality. The Group combats hazardous chemicals including PFAS, targets network efficiency above 80%, and imposes the same discharge thresholds on third-party tenants.

Reference: page 331

For ambient air pollution, Groupe ADP's targets are mandatory and required by local regulation rather than voluntary, with effectiveness monitored annually by prefectural authorities for the Paris airports. The most demanding targets correspond to continuously monitored sites such as the Paris hubs and Amman, with 24/7 monitoring of discharge thresholds, while the least demanding cover correct operation of installations. None of the Group's facilities, given the nature of its energy production and mobility activities, use or emit substances of concern or of very high concern. In 2023 the Group contributed to the fourth atmosphere protection plan (PPA) 2022-2030 for the Paris region, renewed its AIRPARIF partnership and contributed to an AIRPARIF ultrafine-particle study around Paris-Charles de Gaulle. For water, the Group contributes to restoring the quality of aquatic environments at regional, national and European level, with targets mandatory and required by legislation on a site-by-site basis. Thresholds vary by site, season and receiving environment, governed by inter-prefectural and local decrees for hubs including Paris-Charles de Gaulle, Paris-Orly, Almaty, Enfidha, Monastir and Skopje. Responsibility lies with the local Group entity holding the authorisation, monitored annually by prefectural authorities.

Reference: page 332

Air pollution data are direct measurements, with no estimates, of 2024 pollutant flows from the energy-production power plants at Paris-Charles de Gaulle and Paris-Orly only, with rollout to other hubs planned for the 2025 report. Group totals for 2024 were carbon monoxide 8,481 kg, SO2 614 kg, NOx 30,865 kg, suspended particulates 267 kg, CO2 49,362 tonnes and NH3 216 kg. The IED installations subject to heading 3110 are the CTFE and CFEbis energy plants at the two Paris hubs, with no non-compliance incidents in 2024 and quarterly reporting to DRIEAT. Water figures for 2024 are estimates extrapolated from 2023 data using discharged volume, covering about 70% of the Group's scope. Estimated annual flows for the Paris airports include total nitrogen 378,599 kg, total phosphorus 38,448 kg, chlorides 846,189 kg, zinc 950 kg, copper 349 kg and fluorides 1,108 kg, with measurements taken year-round by COFRAC-certified labs and no water-pollution incidents reported. On soil, the Group holds no authorisation to release pollutants into the ground and makes no regular ground discharges, so this IRO was deemed non-material and is covered under the Vigilance Plan. A soil-pollution prevention policy has operated for the Paris hubs since 2012 (updated 2022), supported by a groundwater monitoring network governed by inter-prefectural decrees.

Reference: page 333

None of Groupe ADP's facilities, by the nature of their energy production and mobility activities, emit substances of concern or of very high concern. Aéroports de Paris SA keeps a register of chemical products used at its Paris-region hubs, although this approach is not yet in place for the TAV and AIG Group hubs. Applying Best Available Techniques and seeking to keep occupational and neighbour risks minimal, the Group has a policy of not using hazardous or extremely hazardous chemicals where alternatives exist. Within the limits of its knowledge of commercially available product compositions, the Group states that it does not use any substances of concern or of very high concern on its Paris region hubs. The same statement applies in the water context. On PFAS, identified as toxic and very persistent emerging pollutants historically used in fire-fighting foams, the Aéroports de Paris SA laboratory has worked with partner VALGO since 2022 on a programme including awareness actions in 2022 and a preliminary risk assessment at the Paris airports. Since 2018 the Paris airports no longer purchase fire-fighting products containing PFAS, and the Group engages with authorities and working groups including ACI Europe, the DGAC, BRGM and UAF.

Reference: page 351

Groupe ADP states that its business model recognises the need for a strategy consistent with limiting pressure on biodiversity and resilient with regard to its dependencies. A first step was taken in 2022 by measuring the biodiversity footprint of the Paris airports and identifying direct and indirect pressures. A new study covering the consolidated scope, integrating transition scenarios to analyse resilience, is to be carried out in 2025, with the resilience analysis of the business model scheduled for 2025-2026. Time horizons used are short term, medium term (2026-2029) and long term (2030, 2035, 2040). The Group has set a target of preserving 30% of its surface area for biodiversity, designed to comply with the third target of the Kunming-Montreal Framework. To measure its biodiversity footprint it uses Mean Species Abundance per surface, assessed through the Global Biodiversity Score. The resulting transition plan, once validated by the Executive Committee, will be published by 2027 at the latest.

Reference: page 353

In 2024 Groupe ADP renewed its biodiversity commitments to the act4nature International programme, of which it has been a member since 2018, and reviewed its 2020-2024 commitments. A co-construction phase with employees ran over eight months, involving 17 entities and more than 50 employees, to draw up the 2030 Biodiversity Commitments. The environmental policy underpinning the 2025 Pioneers roadmap positions biodiversity as a key topic. Future commitments are structured around four areas, Protect, Give back, Mobilise and Raise, aligned with the National Biodiversity Strategy and aiming for No Net Loss by 2035 then net gain. The Group applies a voluntary Avoid-Reduce-Support sequence and has pursued a zero-phytosanitary switch for more than ten years. On labels, Paris-Orly holds Aerobio level 3 and the Ecojardin label, making it the largest such airport in France, while Paris-Charles de Gaulle and Paris-Le Bourget hold Aerobio level 2. The Group is recognised by the French Biodiversity Office's Entreprises Engagees pour la Nature. It has committed to incorporating biodiversity Duty of Vigilance clauses into contracts in key purchasing sectors by 2027, and its updated 2024 CSR suppliers' charter includes 13 principles, one on biodiversity preservation.

Reference: page 357

Groupe ADP organises its biodiversity actions over the 2023-2024 period into seven themes. On measurement, the Paris hubs run annual fauna and flora inventories with the Aerobiodiversite association, and in 2024 the Group extended measurement to international airports, with the TAV subsidiary planning ecological inventories for ten sites, including studies launched for Antalya, Almaty, Ankara and Izmir and others planned for 2025. On habitat protection, the Paris hubs honour commitments to preserve 25% of space for biodiversity at Paris-Charles de Gaulle and 30% at Paris-Orly and Paris-Le Bourget. By 2024, 47% of the Paris-Charles de Gaulle hub surface area was managed using late mowing, and all three Paris hubs achieved zero phytosanitary management, a measure first introduced voluntarily at Paris-Orly in 2008. On employee mobilisation, 68% of citizen-involvement actions were carried out with nature conservation associations, 36 employees in animal risk prevention were trained in fauna and flora recognition, and more than 210 employees were made aware of biodiversity through the climate fresco. On offsets, no project required regulatory compensation in 2024. Voluntary restoration includes a project to restore 10 hectares bordering Route Nationale 7 at Orly and 10,000 square metres renatured between 2021 and 2024 under the CDC Biodiversite Nature 2050 programme.

Reference: page 359

The 2025 Pioneers strategic plan contains 10 KPIs dedicated to biodiversity and sets two biodiversity objectives: first, preserving 25% of surface area at Paris-Charles de Gaulle and 30% at Paris-Orly and Paris-Le Bourget; and second, providing Airports for Trust Charter signatory airports with a trajectory to improve their biodiversity index by 2030 compared to 2020. Additional monitored metrics include an ecological-value assessment based on a biodiversity index still under construction, implementation of a local biodiversity strategy, and generalised zero-phytosanitary management. Targets were defined using the SMART methodology, validated by the act4nature jury, and monitored annually internally. They were set in 2020 for the 2020-2025 period on a priori materiality, with materiality to be improved at the 2025 renewal. In 2024 the Group carried out an alignment study against international frameworks, basing itself on the 23 targets of the Kunming-Montreal Framework, the EU Biodiversity Strategy and the French National Biodiversity Strategy, notably measures 24 and 33 aimed at airport hubs. For Kunming-Montreal target 3 it made a commitment in line with the global target. Ecological thresholds will not be processed before 2025, following the planned 2025 biodiversity trajectory study.

Reference: page 361

For the number of sites in or near protected areas or key biodiversity areas on which the Company has a negative impact, Groupe ADP reports land ownership of 0 and sites operated, whether leased or owned, of 30 sites covering a surface area of 12,067 hectares. Earlier in the section, 30 sensitive areas were identified within 13 km of the airports, comprising 8 at Paris-Charles de Gaulle, 2 at Paris-Orly and 6 at Paris-Le Bourget, plus international sites. The land-use metric based on Life Cycle Assessment is non-mandatory and was not processed for 2024. On impact drivers, on the basis of existing data the Group has not concluded that its activities negatively impact land-use, freshwater-use or sea-use change in the identified sensitive areas. It chose bird collisions as the relevant parameter for identifying sensitive biodiversity areas, using a 13 km perimeter defined under EU Regulation No. 139/2014. The Group applies a just culture approach within its Safety Management System, which runs counter to setting absolute collision-reduction targets.

Reference: pages 381, 391, 398

Groupe ADP's workforce policies sit under the 2025-2029 Group HR Roadmap, formalised in 2024 for the first time. For health and safety, the roadmap is translated into a Group OHS Charter approved by Executive Management at end 2024, built on eight fundamental principles covering legal compliance, a prevention culture, annual risk-based action plans, training and ISO 45001 certification (held by nine entities including Paris-CDG, Paris-Orly, Paris-Le Bourget, TAV Antalya and AIG Amman). For securing skills and job attractiveness, the roadmap breaks down into a Skills Development Charter, Mobility Charter and Top Management Charter, to be distributed across the consolidated scope in 2025. Common Human Rights commitments cover safe working conditions, minimum wage, social protection, training, freedom of association and a speak-up culture. Groupe ADP states it has no formal Group-wide social dialogue policy, judging it unsuited to differing national legal requirements.

Reference: pages 383, 393, 398

Engagement runs through both managerial dialogue with employees and formal representative bodies. In France the Social and Economic Committee (CSE) and its specialist committees, including the Health, Safety and Working Conditions Commission (C2SCT) and five local committees, handle OHS, employment, skills and equality matters. The ADP SA CSE meets weekly. Engagement is reinforced by surveys: a triennial Quality of Life at Work survey at ADP SA, Hub One's fortnightly Lucca social barometer, Hologarde's three to four annual surveys, AIG's annual satisfaction survey, and TAV's Great Place to Work survey (certified 2023-2024). Social dialogue and its results are overseen by Executive Management with HR support. Effectiveness is judged by negotiated agreements and accident and absenteeism results. The Group reports no Global Framework Agreement and no particularly vulnerable or marginalised workers identified.

Reference: pages 384, 393, 400

There is no dedicated grievance channel for OHS or for skills and job attractiveness specifically. Accidents resulting in time off work are monitored and analysed by safety prevention officers together with the employee and manager, with corrective measures and action plans applied as needed. The Group's central remediation channel is the whistleblowing system deployed in 2018, available 24/7 worldwide and allowing anonymous or confidential reporting of breaches of the Code of Conduct, including serious harm to Human Rights, fundamental freedoms or personal health and safety under the Potier duty-of-vigilance law (described in section 4.4.2.4). Employees can also approach managers, OHS prevention officers, workforce representatives, occupational health or social services. Awareness and trust in the system are measured annually through the Ethics Climate Barometer, and anti-retaliation protection is in place.

Reference: pages 385, 394, 401

For health and safety, action plans cover safety flashes and road-accident prevention with police, co-activity accident prevention following internal and external audits (baggage galleries, delivery bays), technical-risk site visits, gestures-and-postures training, psychosocial risk reviews in the DUERP and anti-harassment training. A dedicated prevention plan was deployed for the 2024 Olympic and Paralympic Games. From 2025 ADP SA will offer all employees a full health check-up. For securing skills, actions include the Horizon Manageial management programme, a business and skills repository, a professions map updated every two years, a Graduate programme recruiting young graduates on permanent contracts, university partnerships and a Talent marketplace tool in development. More than 50 ADP SA roles are dedicated to environmental and energy projects, with over 80 related training courses offered. Social dialogue actions rest on managerial dialogue and negotiation; no negative impact was identified.

Reference: pages 387, 396, 401

Groupe ADP discloses that no measurable targets have been set for any of its three material own-workforce sub-topics at this stage. For health and safety, no targets are set and performance is tracked through monitored metrics (frequency and severity rates, number of work-related accidents, absenteeism). For securing skills and job attractiveness, no objectives are set, with effectiveness measured through recruitment, mobility, turnover, promotions and training monitoring. For social dialogue, there are no targets beyond the ongoing existence and leadership of dialogue itself. In all three areas the Group states that targets will be considered for the period of the 2025-2029 Group HR Roadmap, accompanied by shared objectives once the Mobility, Skills Development and Top Management charters are implemented. Employees and their representatives are involved through the committees and negotiations described under S1-2.

Reference: page 380

Groupe ADP employed 29,330 people at end 2024 across 16 countries, covering ADP SA, TAV Airports, Hub One, ADP International (including AIG Jordan), the Extime entities and Hologarde. By gender the managed workforce was 19,366 male and 9,964 female, with zero reported as other or not disclosed. By contract type, 27,391 were on permanent contracts and 1,939 on temporary contracts (permanent: 18,217 male, 9,174 female; temporary: 1,149 male, 790 female). The largest geographic concentrations were Turkey (10,867), France (8,641), Kazakhstan (4,423), Georgia (1,414) and Macedonia (1,006). Turnover in 2024 was 8,273 departures, a rate of 32.03%. Headcount is reported as employees managed at period-end, excluding the Chairman and CEO and employees under the RCC end-of-career leave scheme. Data are cross-referenced to Note 5 Employee benefits of the consolidated financial statements.

Reference: page 401

Groupe ADP discloses collective bargaining coverage and social dialogue by coverage band rather than a single Group rate. France falls in the 80-100% band for both collective bargaining coverage and social dialogue, and Kazakhstan in the 80-100% band for collective bargaining coverage, while Turkey sits in the 0-19% band. Social dialogue effectiveness is reflected in six collective agreements signed at ADP SA in 2024, including the NAO 2024 compensation agreement, agreements on the Group Works Council configuration, and an amendment to the men-women professional equality agreement 2023-2026. Extime Duty Free Paris and Hub One also signed agreements covering remuneration, remote working, gender equality and the right to disconnect. Groupe ADP confirms it is not subject to a European Works Council, as it has no European subsidiary employing at least 50 employees.

Reference: pages 380, 402

Gender diversity figures are disclosed in the workforce tables: of 29,330 employees, 19,366 were male and 9,964 female (around 34% women), with none reported as other or not disclosed. Management gender diversity is addressed for ADP SA, where the Board confirmed objectives for 2024-2026 of raising women on the Executive Committee to 33% (25% since September 2022) and 40% across all management committees (eight of which exceeded the objective at end 2024, two above 25%, lowest 17%). Hub One reported 28.4% women in 2024, up from 27.3% in 2022-2023. The diversity, equality and inclusion sub-topic was assessed as non-material under the CSRD methodology and is reported under the Group's extended duty of vigilance. No age-band breakdown of the full workforce is presented in the chapter.

Reference: pages 387, 388

Groupe ADP reports that all consolidated subsidiaries provide social protection aligned with local standards and/or internal Group policies, covering ADP SA, TAV Airports, AIG, Merchant Aviation, Hub One, ADP International, SDA Zagreb and the Extime entities. By category, 100% of workers are covered for health, unemployment, workplace accidents and disability, and parental leave. Retirement protection covers 99.5% of employees, with employees in the USA the exception noted as not benefiting from this protection. All employees on permanent (CDI) or fixed-term (CDD) contracts are covered against loss of income due to sickness, unemployment, workplace accidents, acquired disability and parental leave through local public programmes and/or company benefits. Schemes are set either by national legislation or by internal policies where these offer better cover than local requirements.

Reference: page 404

In 2024, 2.4% of the Group's employees, 703 people, were identified as disabled. Of these, 684 were on permanent contracts and 19 on fixed-term contracts, split 422 male and 281 female. ADP SA reports nearly 35 years of commitment to disability, from its first collective agreement in 1991 to the 11th covering 2023-2026. 2024 initiatives included a repeated Quality of Life at Work survey for disabled employees, new booklets on disability and family carers, awareness events during the SEEPH European disability employment week, a toll-free advice line, support for obtaining RQTH disabled-worker status, and external partnerships such as AGEFIPH and use of the protected sector. Hub One rolled out a new Disability and Inclusion Charter in 2024, and AIG, TAV and SDA Croatia describe further disability inclusion measures.

Reference: page 397

Groupe ADP discloses training and skills development metrics for 2024. The proportion of employees who participated in regular performance and career development reviews was 77.10% overall, 78.41% for men and 74.57% for women. The average number of training hours per employee was 35.86 overall, 28.64 for men and 36.66 for women. The proportion of employees trained, based on the average workforce managed over the period, was 91.16%. Training metrics are calculated on the basis of the average number of employees managed over the period. These figures underpin the skills development sub-topic, supported by the Skills Development Charter, the business and skills repository, the professions map and programmes such as Horizon Manageial and the Graduate programme.

Reference: page 388

Groupe ADP reports that 100% of the workforce is covered by a health and safety management system. In 2024 there were 559 work-related accidents resulting in lost work time, zero fatalities from work-related injuries and occupational illness, five recordable occupational illnesses reported during the year, and 22,761 days lost due to workplace accidents. The frequency rate was 9.80 and the severity rate 0.40. The health and safety management system uses ISO 45001, with nine entities certified: Paris-Charles de Gaulle, Paris-Orly, Paris-Le Bourget, TAV Airports AYT (Antalya), Havas, TAV OS Airports, ESB (Esenboga) and AIG (Amman). Internal audit activities apply Groupe ADP's Life Safety key controls manual across the Group, with the Audit, Security and Risk Management Department certified by IFACI.

Reference: page 410

Groupe ADP covers two material matters for value chain workers: occupational health and safety (OHS) and securing and making jobs and skills attractive. The OHS policy is set out in a Group-wide OHS charter validated by General Management at the end of 2024, to be communicated in 2025, and extends to value chain workers on Group sites. The Group purchasing policy, signed by all subsidiary CEOs between 2022 and 2023, embeds a CSR and OHS dimension at each stage of purchasing. ADP SA also has a Responsible Purchasing and CSR Policy, being revised for Group-wide application from Q1 2025 to reflect CSRD and CSDDD requirements. Human Rights commitments are anchored in the Supplier, Service Provider and Partner CSR Charter, signed by all contract holders, and reference the UN Global Compact, the UDHR, the eight fundamental ILO conventions, the OECD Guidelines and the UN Guiding Principles. In France, 96% of ADP SA suppliers comply with local regulations. A new CSR charter for suppliers, service providers and partners was due to be published in Q1 2025. No cases of non-respect of these instruments are known to date.

Reference: page 412

Current legislation (the Public Order Code) prevents Groupe ADP from establishing a subordinate relationship with value chain workers, so engagement is conducted with their legitimate representatives or credible proxies throughout the consultation, performance, assessment and social audit phases of contracts. The social CSR sub-criterion alone carries 5% of the overall weighting of bid scores at ADP SA. Engagement covers HR managers of bidding companies, contract signatories, operational managers, employees of signing companies and workers on operational sites. Engagement stages include contract signature, production of prevention plans, annual training and awareness sessions, and on-the-spot checks on PPE use and safety practices. Since 2024, awareness sessions have been extended to road safety at the initiative of the HR Department. During performance, commitments are assessed through Supplier Performance Measurement (SPM) sessions and social audits. Purchasing departments such as ADP SA's PLSD survey strategic suppliers (for example the Top 100) approximately every 18 months. Effectiveness is judged by the absence of any serious or fatal accident at Group airports under the operator's responsibility since 2022. The risk analysis did not identify any particularly vulnerable or marginalised worker groups.

Reference: page 414

Groupe ADP provides all value chain stakeholders, including the authorised representatives of contracting companies' employees, with a virtual ethical and social alert system to raise concerns about working conditions. Alerts are followed up by the Group Ethics Department. The Group whistleblowing system enables reporting of any breach of the Code of Conduct, in particular serious infringements of Human Rights and fundamental freedoms within the scope of the Potier law on the duty of vigilance. This system, already accessible to contract holders and their employees on the Group website, is referenced in the 2025 edition of the Supplier, Service Provider and Partner CSR Charter. Social matters recorded by the alert system include occupational health and safety risk, workplace discrimination, harassment, and breaches of the labour code. Any repairs comply with the current legislation and labour code of the countries where Groupe ADP sources its value chain. The whistleblowing system ensures the confidentiality of communications and the protection of whistleblowers against retaliation. For the skills and attractiveness matter, ADP SA reports the grievance disclosure requirement as not applicable.

Reference: page 415

The OHS action plan, drawn up by each entity within its operational scope, builds on existing operational practices. Planned actions include extending OHS measures across the full scope of consolidation, addressing chain subcontracting, deploying OHS risk assessment using a standard CSR grid, and real-time collection of service provider accident data. From 2025, ADP SA will collect and consolidate accident data periodically; from 2026 the system will be completed by on-site audits of suppliers in countries outside France, requiring an additional budget. Actions include OHS requirements in technical specifications (CCTP), a CSR/social evaluation system for bids, co-signed prevention plans, and a workplace accidents alert system that escalates orange and red alerts to the Executive Committee. Two orange alerts and one red alert were recorded in 2024, each giving rise to documented analyses. The Prevention is success guide defines 12 safety standards for work sites. For the skills and attractiveness matter, no material negative impact has been identified; positive actions include a commitment to at least 80% local purchases including 20% from SMEs, with ADP SA acting as an HR integrator for the airport community.

Reference: page 416

Groupe ADP does not have time-limited objectives for occupational health and safety, but states a permanent commitment from the entire hierarchical line, from the Chairman and CEO to all managers and employees. This commitment rests on four golden rules of safety: prevent any serious accidents (with after-effects) or deaths; reduce accidents on a long-term basis; offer personalised health and safety support to employees; and manage major OHS risks. The defined objective is the prevention and avoidance of any occupational accident likely to harm the physical integrity of value chain workers, Group employees, customers and other stakeholders present on or near sites. Employee representatives can express their views during surveys carried out by purchasing departments such as ADP SA's PLSD among strategic suppliers (for example the Top 100), conducted every 18 months, which include targets where defined and outcomes. For the skills and attractiveness matter, there are no collective or macro targets shared across purchasing segments; service quality standards are defined at the level of each contract and monitored through Supplier Performance Measurement (SPM) for the ADP SA and AIG scope.

Reference: page 425

Groupe ADP identified three material matters for affected communities: reducing noise pollution, quality of dialogue with local stakeholders, and local economic development, employment and integration. The noise reduction policy, implemented as part of the Vigilance Plan, has two strands: reducing noise at source and reducing the sound impact on local residents through a soundproofing assistance scheme. Public noise management policy is set internationally by ICAO resolution A33/7 (the balanced approach), applied in Europe through EU Regulation 598/2014 and in France through Noise Protection Plans (PPBE) and, as a last resort, Balanced Impact Assessments (EIAE). The home soundproofing scheme was introduced in France by the law of 31 December 1992, financing work according to exposure zones 1, 2 or 3. The dialogue policy is embodied in the Maisons de l'Environnement, the Environmental Consultation Committee and voluntary consultations such as the Paris-Orly master plan consultation, which covered 104 municipalities across departments 91, 92, 94 and 77. The economic development policy is anchored in the Airports for Trust charter, signed by 23 Group airports in January 2021, and Axis 3 of the Pioneers for Trust CSR policy. No indigenous peoples were identified on the Group's rights of way.

Reference: page 426

French airports have Environmental Consultation Committees, chaired by the departmental prefect, that coordinate three boards: local elected representatives, residents' and environmental associations, and aviation professions. These committees meet twice a year, with secretarial duties provided by ADP SA, and give opinions on the PPBE and EIAE. Engagement occurs with legitimate representatives of affected communities, each board appointing its representative, and directly with applicants for soundproofing assistance. For example, residents' associations helped identify improvements to airline operating procedures such as early landing gear extension. The Advisory Committees for Assistance to Noise Reduction (CANR) handle financial aid. The Maisons de l'Environnement operate around forty permanent noise measurement stations and promote the Vitrail software for identifying overflights, with monthly measurements sent to ACNUSA and the DGAC. At AIG, communities contact staff via ehs@aig.aero and at annual meetings; at TAV Airports Almaty, applicants use the Noise Insulation Program form. For economic development, ADP SA engages institutional players, associations, training organisations and education authorities. Operational responsibility lies with airport directors and the Deputy Managing Director for Sustainable Development and Projects.

Reference: page 428

For noise pollution, the general approach combines a soundproofing assistance and transparency policy with an annual quality survey of residents who have benefited from the scheme. Specific channels include public information meetings at the Paris-Charles de Gaulle and Paris-Orly Maisons de l'Environnement and the EntreVoisins website, where residents can use the VITRAIL tool to view air traffic or submit an ITRAP form to query overflights. Unmarked email addresses such as environnement.cdg@adp.fr allow direct personalised dialogue. TAV Airports and AIG have no specific noise channel, but concerns can be raised through non-specific channels or the Group whistleblowing system. Each soundproofing case is monitored centrally in a dedicated IT tool in compliance with GDPR. A quality assessment found that 70% of residents considered noise unbearable before works, while 99% considered it acceptable after works. The complaints tool registers several hundred complaints a year. ADP SA can handle anonymous requests from residents' associations. For economic development, no material negative impacts have been identified; channels are based on region-based partnerships governed by boards of directors, technical committees and steering committees. The Group whistleblowing system guarantees no reprisals.

Reference: page 429

ADP SA coordinates the soundproofing assistance scheme financed by the Taxe sur les nuisances sonores aériennes (TNSA) for Paris-Orly, Paris-Charles de Gaulle and Paris-Le Bourget, which has soundproofed 74,000 homes since 2003. Resources support around 2,000 homes and buildings on an ongoing basis. In 2024, 566 new requests were accepted by the ACLR and 1,900 homes were soundproofed for a total of 19.4 million euros in aid. Actions include a certified in-house laboratory (around 60 staff, including about five dedicated noise experts) operating measurement stations such as 24 within 25 km of Paris-Charles de Gaulle, modulation of airport charges since April 2022 to favour quieter aircraft, the Maisons de l'Environnement, and the FCNA local assistance fund. Around 15 experts are dedicated to managing the soundproofing scheme. At Paris-Charles de Gaulle the IGMP noise index has fallen sharply, reaching 66.7 in 2019. AIG found noise contained within the airport area (immaterial), and TAV Airports allocated over USD 3 million to its Almaty Noise Insulation Program. For economic development and employment, no material negative impacts or opportunities were identified; a five-year financial support plan worth 90,000 euros was put in place for 2024, and the Aerowork initiative placed more than 1,000 people in airport jobs (92% on permanent contracts).

Reference: page 432

For noise reduction at Paris-Charles de Gaulle, targets will be set at the end of the EIAE exercise using two Directive 2020/367 metrics: a first target to reduce people severely affected over a full day (HA55) by a third, between 28% and 38%, and a second target to halve those affected at night (HSD50), a reduction of between 45% and 55%, with a tolerance of plus or minus 5%. For Paris-Orly, targets set in the PPBE 2018-2023 (approved by decree of 17 March 2022), against the 2018 reference and the return to 2018 traffic estimated in 2026, are a reduction of at least 6 dB in average Lnight value during 10 p.m. to 6 a.m. in the Lnight above 50 bracket, and a halving of the High Sleep Disturbance (HSD) indicator. The environmental alliance launched in 2023 at Paris-Orly, with 38 partners, set a target of 6 dB reduction at night (10 p.m. to 11.30 p.m.). For the quality of dialogue matter, there are no targets beyond proper implementation of the policy. For economic development, there is no Group target within the meaning of the ESRS; ADP SA monitors metrics including business start-up rates, incubator occupancy, regional young people on placements, recruitment via Aerowork, and the proportion of local staff.

Reference: page 450

Groupe ADP identified three material matters for consumers and end-users: public and airport safety and security, access to hubs and multimodality, and hospitality for all. Safety and security policy applies the highest air transport standards and aligns with the 2025 Pioneers roadmap. Aviation safety and security standards are set globally by ICAO (Annex 17 to the Chicago Convention), interpreted in the EU by Regulation 300/2008 and Regulation 2015/1998, and in France implemented by ADP SA under State supervision, with airport directors holding delegated authority. Measures include the Vigipirate plan, screening of persons and baggage, video-surveillance and patrols, and a specific legal framework for security scanners protecting dignity and privacy. The access and multimodality policy is governed by access management policies for each Paris hub and an air-rail intermodality roadmap, with airport access modes free to use. Hospitality for all is anchored in the corporate purpose Welcoming passengers, operating and designing airports, in a responsible manner and throughout the world, the Hospitality policy, the Extime brand, the PSH (people with disabilities) roadmap and the Real Estate Department 2024/28 roadmap. The Group joined the Hidden Disabilities Sunflower initiative in 2024. No whistleblowing reports were issued by or concerning consumers or end-users.

Reference: page 477

For safety and security, those involved organise regular situation updates, steering committees and action plans with the prefecture and government departments; passengers can report abnormal situations, while aeronautical safety has no end-user interaction process but uses hub governance bodies and a safety event notification system. For access and multimodality, ADP SA engages travellers, workers (taxis, vehicles for hire, car rental firms), and surrounding regions through numerous meetings, the ADP/IDFM joint action plan monitored annually since 2023, and the Stakeholder Committee of 16 external experts created in 2021. For hospitality, Groupe ADP uses the ACI ASQ survey (carried out since 2007 in nearly 400 airports, with an estimated 26,000 surveys at Paris airports in 2024, up 30% on 2023, and more than 47,000 ASQ-ACI surveys across the Group in 2023), an arrivals barometric survey of around 20,000 interviews a year, a Skytrax partnership with annual audits, mystery visits, and a Customer Community of 1,000 customers. Google Reviews, social networks and 3950 complaints are analysed. A quarterly Service Quality Committee, chaired by the Customer Department, and an international Service Quality Committee set up in 2024 with TAV Airports and AIG oversee engagement. The Consultative Committee for People with Disabilities (CCPSH) will be replaced in 2025 by a Strategic Committee on Accessibility.

Reference: page 479

Feedback from consumers and end-users is channelled through the 3950 telephone hotline, a contact form on the Paris Aeroport and extime.com websites, the mobile application, social networks, and postal mail, with support for English and French speakers. A dedicated freephone number serves car park users. The Group whistleblowing system enables reporting of breaches of the Code of Conduct, including corruption and fraud (Sapin II law) and serious infringements of Human Rights, fundamental freedoms or health and safety (Potier law on the duty of vigilance). Paris-Aeroport handles 100% of complaints from end-users at Paris-Charles de Gaulle and Paris-Orly with rapid processing, and a quarterly review is shared with stakeholders. For example, a service quality deterioration at terminal 2F in April 2024 triggered an action plan covering space saturation, seating and cleanliness. In 2023, Aeroports de Paris handled 99.7 million passengers and 292,000 customer calls, with nearly 75,000 discussed with advisers (down 27% versus 2022) and around 18,000 complaints from other channels; in 2024 TAV Airport handled more than 17,000 calls (up 53% versus 2023). The company is a member of the Tourism and Travel Ombudsman (MTV), accepts anonymous requests for information, and ensures GDPR compliance and protection against retaliation.

Reference: page 454

For safety and security, ADP SA operates a Safety Management System (SMS) and internal monitoring at each hub to maintain the airport safety certificate, with hub risk maps and continuous adaptation of security programmes (approved by prefectural decree for five years). Around 250 ADP staff perform security duties directly and nearly 5,000 work for external service providers. Olympic Games measures in 2024 included around 1,000 additional cameras, extended drone detection, EDS Cabin baggage screening, and Red Cross day centres for the homeless. For access and multimodality, four action plans operate: the parking action plan, the mobility action plan, the air-rail intermodality roadmap and the ADP/IDFM action plan, led by the Master Planning and Mobility department (a five-person Mobility division). Actions include new car parks, more than 700 electric vehicle charging points, cycle paths, and supporting metro lines 14, 17 and 18, CDG Express and Roissy-Picardie. For hospitality, action plans cover service quality (using Skytrax and ASQ-ACI results, a courtesy and helpfulness plan, modernised check-in and PARAFE lines) and accessibility for all (Families Action Plan, sunflower lanyard, e-learning disability training for all employees, guidance systems for the visually impaired planned for 2025, accessible changing rooms, and the Real Estate 2024/28 roadmap).

Reference: page 469

For safety and security, ADP SA commits to a safe flight with the best possible comfort; some targets are confidential and form part of its own safety and security management system. For access and multimodality, targets include a 29% increase in the modal share of public transport for Paris-Orly passengers by 2035 and a 27% increase for Paris-Charles de Gaulle passengers by 2050, more than 50% of parking bookings made online in 2025, an ACI ASQ score above 3.85 for car park quality, and electric vehicle charging stations reaching 1,000 points in 2025 and 2,500 by 2030. The 2025 Pioneers roadmap also targets a 50% increase in train-air connecting passengers at Paris-Charles de Gaulle and a doubling at Paris-Orly. For hospitality for all, targets are to place Paris-Charles de Gaulle in the Skytrax top 10 world airports, with 4 Group airports in the top 50 and 8 in the top 100; to achieve an ASQ-ACI score of 4 out of 5 for passenger satisfaction at controlled airports with over 3 million passengers; to deploy the Extime Retail and Hospitality concept in Paris and beyond; to provide 50% of passengers with biometric facilitation; and to train all airport community members on the needs of passengers with disabilities. Consumers and end-users are not directly involved in setting or tracking targets, though customer feedback informs them.

Reference: page 497

Groupe ADP's Ethics and Compliance programme has had a Code of Ethical Conduct since 2019, available in nine languages on the intranet and website and binding on all controlled entities. It covers corruption and influence peddling, conflicts of interest, gifts and invitations, data protection and whistleblowing, and integrates the 10 UN Global Compact principles. The Code was last updated in July 2023. It is supplemented by a personal data protection policy, a Vigilance Plan and various procedures. Culture is driven through training, awareness and a speak-up culture, supported by a network of 26 Ethics and Compliance Officers and 20 parent-company coordinators (CARE). In 2024, 52 communication actions were carried out (up from 23 in 2023). An Ethics Climate Barometer surveys more than 3,000 employees annually. The Ethics Committee, comprising 16 Group representatives and two external experts, met twice in 2024. Commitment letters are signed by Executive Committee members and subsidiary leaders. ADP SA also participates in Transparency International (since 2008) and Global Compact France (since 2003).

Reference: page 486

Groupe ADP manages supplier relationships through its Group Purchasing Policy (signed across the consolidated scope in 2022) and a Sustainable and Responsible Purchasing Policy. Purchasing risks are mapped using the Kraljic methodology across 450 purchasing segments, covering ten environmental and four social/Human Rights risk areas. A Supplier and Partner CSR Charter is incorporated into contractual documents, with 100% of contracted ADP SA suppliers signatories and between 66% and 100% across consolidated entities. A third-party evaluation tool flagged 0.2% of ADP SA suppliers as potential high risk. In 2024, 96% of ADP SA contracts included CSR criteria (up from 84% in 2022), targeting 100% by 2025, and 90% of critical contracts were covered by social and environmental audits. Local purchases within 150 km of Paris reached 84.20%. The PNM+ purchasing network, launched in 2021, brings together purchasing managers across consolidated and non-consolidated entities monthly. Supplier audits are conducted by a law firm to verify contractual commitments.

Reference: page 506

Groupe ADP's anti-corruption programme meets the requirements of the French Sapin II law and is built around corruption risk mapping carried out every three years (latest in 2024), with newly integrated entities mapped within a year. A whistleblowing system, opened on 1 October 2018, is accessible 24/7 to employees, contractors and suppliers; in 2024 the Group handled 90 reports, 30 deemed admissible. The Director of Ethics and Personal Data handles reports independently, reporting directly to the Chairman and CEO, supported by a separate trained in-house investigation team and a processing committee. In 2024, 20 categories of functions exposed to corruption risk were identified across 289 functions. 100% of at-risk employees are covered by the training plan; the general e-learning module has been taken by more than 10,000 employees since 2019, with 94% completion under the 2025 Pioneers roadmap and 95% in 2024 for profit-sharing. Training spans four modules covering suppliers, authorities and free competition. Anti-corruption key controls have run since 2023.

Reference: page 507

Groupe ADP reported zero confirmed incidents of corruption or bribery in 2024. There were no convictions for breaches of anti-corruption and anti-bribery laws (0) and no fines (0). The number of confirmed incidents in which the Group's own workers were dismissed or disciplined for corruption or bribery-related incidents was 0, and the number of confirmed incidents relating to contracts with business partners that were terminated or not renewed due to corruption-related offences was also 0. The Group states there are no legal disputes concerning corruption or bribery. Separately, in 2024 Groupe ADP received confirmation that a previous World Bank sanction had been lifted, and the Group reports it has never had to terminate an established business relationship for ethics or compliance reasons.

Reference: page 492

Groupe ADP discloses supplier payment practices within its Sustainable and Responsible Purchasing section. As part of its Responsible Purchasing and Supplier Relations (RFAR) label commitments, ADP SA's PLSD commits to treating suppliers fairly and respecting contractual payment deadlines. CSR Committees between the Accounting and Purchasing departments meet around six times a year to review payment times by supplier type, including VSE-SMEs, ETIs and key accounts. For the past two financial years, the French organisation ALTARES singled out Groupe ADP as the company with more than 500 employees with the best supplier payment compliance rate, above 97% and reaching 98.10% in 2024, compared with around 90% for large groups in favourable cases. Late payments were scrutinised fortnightly in 2024. The compliance rate with payment deadlines rose from 86.43% in 2022 to 97.40% in 2023 and 98.10% in 2024, against a 100% target. Intelligent electronic invoicing is due to roll out in 2026. An internal mediation system handles supplier disputes before legal action.