Aéroports de Paris SA

Governance roles

Reference: page 221; composition, diversity and skills datapoints incorporated by reference to Corporate Governance Report sections 3.1.3.1-3.1.3.2 (cross-reference table, page 220).

"The Board of Directors is the body responsible for monitoring impacts, risks and opportunities. It is assisted by the Audit and Risks Committee" (page 221). That committee "examines the impacts, risks and opportunities" and monitors internal control and risk management.

Board at 31 December 2025 (page 221): 17 non-executive and 1 executive member; one third employee directors under the Act of 26 July 1983; 38.10% female / 61.90% male; 29.41% of non-executive directors independent.

Four committees exist - Audit and Risk, Strategy, Compensation/Appointments/Corporate Governance, and CSR (page 196). The Board's ESG Committee "meets at least once a year and as often as required. In 2025, it met eight times with an attendance rate of 92%" (page 243). Each director is entitled to training "regarding... its challenges in terms of corporate social and environmental responsibility" (page 221). Sections 3.1.3.3.1.1 and 3.1.3.3.2.8 are flagged as meeting datapoint ESRS 2-GOV-1-22-(b) (pages 190, 196).

Information provided to and matters addressed by governance bodies

Reference: page 221; climate governance page 243; reporting calendar page 411.

"The Board of Directors examines on a regular basis, and in light of the strategy it has set, all opportunities and risks including financial, legal, operational, social and environmental risks and the measures taken as a result" (page 221). "Our governance bodies take full account of sustainability matters in their strategic thinking and when examining files."

On climate, "Each year Groupe ADP's Board of Directors examines the implementation of the Group's CSR strategy, which is accompanied by an action plan and the time horizons within which these actions will be carried out"; the Paris-Orly 2035 and Paris-CDG 2050 master plans, "including the major challenges of the ecological transition", were Board-approved (page 243).

Dated items reaching governance in 2025 (page 411): the Ethics Climate Barometer (Executive Committee 2 June, CSR Committee 5 June); the Sustainability Report including the Vigilance Plan (Executive Committee 7 February, Audit and Risk and CSR Committees 14 February, Board 19 February); the Human Rights Policy (Board 15 October); and the annual Ethics and Compliance report (Board 17 December).

Sustainability-related performance in incentive schemes

Reference: page 221; climate detail page 243.

"The incentive schemes are based on the variable portion of the remuneration of the people concerned: the Chairman and Chief Executive Officer and the Chief Operating Officer" (page 221). CSR objectives (environmental and social matters) carry a 25% weighting in the variable component of the Chairman and CEO's remuneration; environmental objectives account for 20% of the Chief Operating Officer's variable remuneration. Board members receive only a fixed fee per meeting attended (EUR 1,700, or EUR 2,500 for committee chairs and the Lead Director).

"Sustainability metrics with performance targets are used to define the objectives (e.g. work accident frequency rate)." Targets are set by the Board on the recommendation of the Compensation, Appointments and Governance Committee and "are subject to approval by the Annual General Meeting, both ex-ante and ex-post".

Climate is quantified: "The maximum gross variable annual remuneration for the Chairman and Chief Executive Officer of ADP SA is EUR 100,000, 12% of which is based on the integration of climate change matters into Groupe ADP's strategy" (page 243).

Statement on due diligence

Reference: page 223.

Groupe ADP presents a due diligence mapping table headed "The reasonable steps to be taken for each phase as set out in the table below", setting the core elements of due diligence against both the stages of the CSRD report and the specific references for the Vigilance Plan (page 223).

Examples of the mapping: "Identifying and assessing adverse impacts" points to section 4.1.3.3 (IRO analysis methodology), 4.1.3.4 (duty of vigilance risk analysis), 4.2.6 (environmental vigilance), 4.3.5 (Human Rights) and 4.4.2 (suppliers and contractors). "Stakeholder engagement" points to section 4.1.3.2 plus the S1-2, S2-2, S3-2 and S4-2 engagement disclosures, counting the matters covered in each (three for S1-2, two for S2-2, three for S3-2, two for S4-2). "Remediation of negative impacts" points to E2-2, E4-3, S1-4 and S2-4 alongside the vigilance-plan sections on soil and groundwater pollution, water consumption, circular economy and child and forced labour.

The report is built on the deliberate merger of the Sustainability Report and the Vigilance Plan, with a pictogram marking vigilance-only sections and a detailed cross-reference table at section 4.5 (pages 216, 431-432).

Risk management and internal controls over sustainability reporting

Reference: page 222.

"The risk management and internal control system used in the Sustainability Report is in line with the Group's overall approach to controlling its activities... As part of the process of adapting reporting to the CSRD, the Audit, Security and Risk Management department has adapted existing processes to meet its requirements. In order to identify the risks inherent in the preparation of the Sustainability Report, Groupe ADP set up a CSRD project team, which includes representatives from all the Group's departments" (page 222).

2025 developments: "During the year, a key controls manual for non-financial processes was drawn up with the support of a specialist firm. This manual describes the main controls to be implemented (levels 1 and 2) on environmental, social and governance processes"; "Tests were carried out by the Group's internal control teams at the end of 2025/beginning of 2026"; "Group Internal Control carried out checks on data points (DP) at the end of 2025" and "worked on an initial analysis of the DMA".

The company states plainly that this second application of Article L. 233-28-4 "is characterized by uncertainties regarding the interpretation of the laws and regulations, the absence of established practices in particular for the double materiality assessment, and an internal control system that is being adapted" (page 218).

Strategy, business model and value chain

Reference: pages 224-225; value chain pages 240-241.

"At 31 December 2025, Groupe ADP operated a network of 26 airports in 17 countries. Its activities are divided into five reporting segments: aviation, retail and services, real estate, international and airport development" (page 224).

Revenue 2025, EUR million (page 225): total 6,704; Aviation 2,192; Retail and Services 2,159; Real Estate 358; International and airport developments 2,147.

Fossil fuel activities (page 225): EUR 299 million - oil 283, gas 15.3, coal not applicable. The Group is "active, in a residual manner, in the fossil fuels sector" through "the purchase and resale of fuel oil in Almaty" and "the purchase of natural gas (of fossil origin in 2025) to produce heat" (page 224).

Strategy is the "2025 Pioneers" roadmap and "2025 Pioneers for Trust" CSR plan, with four objectives (environment, regions, employer, governance) and contributions to 11 UN SDGs; "The actions to be deployed in 2026, the year of preparation for a new strategic cycle that is due to begin in 2027, will be part of this pathway" (page 224). Workforce is 30,333 (page 333). The value chain covers the Airport, Real Estate and Retail and Services chains, the latter two "driven by the needs of the Airport value chain" (page 218).

Interests and views of stakeholders

Reference: pages 226-227.

"Groupe ADP has identified seven main categories of stakeholders" (page 226): customers (passengers and companions, airlines, real estate tenants and airport companies), employees and airport-company staff, public sector organisations, regional development players, directors and financiers, airport partners, and community relays and social influencers. Page 227 tabulates the consultation methods and information tools for each.

Key channels include a Stakeholder Committee created in 2021 made up of 14 experts from civil society (page 226; described at page 243 as 16 independent experts, meeting on 20 March, 19 June, 9 October and 11 December 2025); large-scale consultations for transformation projects (CDG&Vous, Paris Orly 2035); the Economic Advisory Committee for airlines; Environmental Consultation Committees and the entrevoisins.groupeadp.fr site for local stakeholders; and the Ethics Climate Barometer for employees.

"Feedback from stakeholders is always analysed and assessed according to criteria specific to each department... It is taken into account in preparing the strategy, the risk mapping and double materiality assessment in particular. ...The recommendations made by the Stakeholder Committee are analysed and those that are accepted are the subject of monitoring on their implementation, which is presented to the committee members every six months" (page 227).

Material impacts, risks and opportunities

Reference: pages 236-239 (IRO register), 241 (value chain summary), 229, 225.

Section 4.1.3.5 tabulates every material IRO with its ESRS standard, Appendix A sub-theme, sustainability matter, description and time horizon. Page 241 lists them against the value chain under four headings - 14 risks, 3 opportunities, 9 negative impacts and 8 positive effects, 34 in total.

Material standards and matters (pages 236-239): E1 (climate change adaptation; climate change mitigation; developing new energy sources), E2 (air quality; water pollution), E4 (pressure on biodiversity; land artificialisation), S1 (health and safety; skills and attractiveness; diversity; social dialogue), S2 (value chain worker health and safety; skills and attractiveness), S3 (noise; dialogue with local stakeholders; local economic development), S4 (public and airport security and safety; service quality; access and multimodality), G1 (prevention of ethics and compliance risks including corruption).

A new material matter was added in 2025: the Group's positive impact on diversity, "for the company and its employees, the impact is positive by giving as many people as possible the opportunity to enter and remain in employment" (page 229).

Processes to identify and assess material IROs

Reference: pages 228-229; duty of vigilance methodology pages 229-235.

The DMA was first carried out in 2024 in three stages (page 228): identification of relevant topics via a 2023 stakeholder questionnaire ranking 21 CSR matters - "Over 1,000 responses were received" - supplemented by expert interviews, then in Q1 2024 "taking as a reference the list of 89 sustainability matters provided by the CSRD (see AR-16-ESRS1)"; scoring and consolidation; and validation.

Methodology: the Audit, Safety and Risk Management department "adapted the existing risk rating scale so that the various ESRS managers could use it to rate the positive and negative impacts, risks and opportunities". The grids comprise a probability scale (unlikely to very likely), a financial-materiality extent scale "derived from the grid usually used for rating risks at Groupe ADP", and for impact materiality "a triple assessment scale covering the scale, scope/extent and irremediability of each topic... resulting in an average rating". "Groupe ADP has occasionally grouped together related topics" (page 228).

Validation runs through the Risk, Opportunities and Internal Control Committee (CORCI) and the Executive Committee, then "with the governance bodies, at a joint Audit, Risk and CSR Committee and at the Board of Directors' meeting when Groupe ADP's risk map was presented" (page 229).

Disclosure requirements covered by the sustainability statement

Reference: pages 220, 229. Caution: this report prints no ESRS content index or IRO-2 concordance table.

Groupe ADP states the presentational change: "The choice of a presentation based on Disclosure Requirements (DR) rather than Data Points (DP) is the major change in this new report, and is intended to improve its readability" (page 218). Coverage is declared instead by bracketed ESRS datapoint references printed in the margin of each subsection - for example "[2-GOV-1-19] [2-GOV-1-20] [2-GOV-1-21] [2-GOV-1-22]" (page 221) and "[E1-6-44] ... [E1-6-55]" (page 265). The IRO-2 datapoints themselves are tagged at page 229.

The only DR-level table is the short "List of DRs & DPs" on page 220, introduced as "The table below summarises the publication requirements that are cross-referenced in the URD". It maps seven ESRS 2 subjects to the management-report sections incorporated by reference; it is not a complete content index with page references per disclosure requirement. Section 4.5 (pages 431-432) is a Vigilance Plan cross-reference table keyed to the Potier law, not to the ESRS.

Transition plan for climate change mitigation

Reference: pages 255-258; resources pages 284-285; levers and CapEx page 286.

"Transition plans have been drawn up for seven airports (out of the 15 in the consolidated scope), representing 81.4% of the Group's GHG emissions in 2025... Although these transition plans are not currently consolidated into a single group transition plan, Groupe ADP's consolidated hubs share a common climate change mitigation strategy... and common decarbonisation levers" (page 255). "Groupe ADP aims to have a consolidated transition plan at Group level in 2027", including "a single overall greenhouse gas emissions reduction target for the financially controlled scope".

Scope 1 and 2 levers (page 255): energy efficiency; thermal renewables; Guarantees of Origin / RECs plus photovoltaic; vehicle fleet. Estimated 2025 CapEx to 2035 for the Paris airports is EUR 220m-280m with annual OpEx of EUR 7m-11m (pages 256, 286).

Scope 3 levers with weightings (pages 256-258): new sustainable aviation energies 78.4% of Group Scope 3; greening airside activities 6.3%; rail/air intermodality 9.5%; lower-carbon construction 0.9%; plus offsetting. Named investments: GLORYA and ClearCDG airside electrification at EUR 34m and EUR 40m, with "An additional investment of more than EUR 250 million" required; EUR 240m for the Paris-Orly metro line 14 station; EUR 227m for CDG Express.

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 and SBM-3 as applied to E1 and from the climate adaptation section, where this content is disclosed in the FY2025 report (pages 245-248, 254). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against; the datapoints tagged there are [E1-ESRS 2 IRO-1-20], [E1-ESRS 2 IRO-1-21], [E1-ESRS 2 SBM-3-18] and [E1-ESRS 2 SBM-3-19].

Classification. Three material climate matters: adaptation, mitigation and the development of new energy sources (page 245). Studies cover "the risks and opportunities of the transition to a low-carbon economy" and "physical risks, which include the direct effects of climate change, whether chronic... or extreme".

Methodology. Transition risks were identified for short (one year), medium (2030) and long (2050) term, ranked by horizon, magnitude and effort, and structured under the four TCFD categories (page 246). Physical risk was assessed in two phases: gross risks for all 26 airports between 2022 and 2024, then net and residual risk studies (page 247).

Resilience in relation to climate change

Back-filled from ESRS 2 SBM-3 as applied to E1 and from the adaptation strategy, where this content is disclosed in the FY2025 report (pages 245, 249-255). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

Results (page 245). "The results of the climate risk analysis have been taken into account to strengthen the resilience of the Group's strategy and business model in a number of ways": the transition analysis "confirmed the value of the two main angles for transforming the airport model into an energy hub and/or a multimodal hub"; it "highlighted the need to strengthen the energy sovereignty of airport hubs"; "a climate risk analysis will be carried out, where appropriate, for any significant investment project or concession merger/acquisition"; and "a resilience analysis was also carried out by means of an impairment test (impact on traffic, investments, expenses and assets)".

2025 work (page 249). Net climate risk analyses were finalised for the three Paris airports and the three most at-risk international airports (Amman, Izmir-Adnan Menderes, Milas-Bodrum), identifying "the critical assets, systems and services with the greatest vulnerabilities up to 2030 and 2050" and prioritising measures on cost/benefit and feasibility. A detailed adaptation plan for the French assets was finalised in line with PNACC3.

Policies related to climate change mitigation and adaptation

Reference: pages 249, 258; datapoints [E1-2-22] to [E1-2-25].

Climate policy sits inside the environmental pillar of the 2025 Pioneers for Trust CSR policy, itself built on the 2021 Airports for Trust charter "signed and supported by 23 of the Group's airports worldwide" (page 242). That pillar comprises four ambitions - "work towards zero environmental and energy impact in operations within our scope of responsibility (extended to concessions)", taking "an active part in the environmental transition in the aviation sector", promoting "the integration of each airport in a local resources system", and reducing "the environmental footprint of airport activity planning and development projects" - delivered through 15 commitments.

"Three of the four areas of environmental policy are directly related to the climate: move towards operations with zero environmental impact; actively participate in the environmental transition in the aviation sector; reduce the environmental footprint of airport activity planning and development projects" (page 258).

Actions and resources in relation to climate change policies

Reference: adaptation pages 249-254; mitigation pages 274-286; datapoints [E1-3-26] to [E1-3-29].

Adaptation actions in 2025 (page 250): completion of the CanaMarne rainwater project and drainage renovation; chilled water production capacity at Paris-Orly raised "from 22 to 40 MW"; geothermal works at Paris-Charles de Gaulle, connection of Paris-Le Bourget to the Dugny-Le Bourget geothermal network, a second 225 kV supply at Paris-Orly planned for 2026, and photovoltaic plants at Izmir and Milas-Bodrum; an updated heatwave alert procedure; and a flood-prone area map at Paris-Orly.

Mitigation, Scopes 1 and 2 (pages 274-276): the energy efficiency plan delivered "-14% on electricity consumption" and "-38% on heating consumption" at ADP SA at end-2025 versus 2019. Two wood-fired boilers supply 25% of Paris-CDG heat (47 GWh/year); the deep geothermal plant commissioned in 2026 "will produce 80 GWh per year to cover 32% of the hub's heating needs"; a heat pump makes the Paris-Orly network "74% carbon-free"; Paris-Le Bourget's geothermal connection "will provide a heating network that is 90% carbon-free". Three Urbasolar plants totalling 36 MW covered 10% of Paris hub electricity at 99% availability; a 4.8 MW plant was inaugurated at Amman in April 2025; the Paris-Orly winter service fleet "has been running on 100% HVO since October 2025".

Targets related to climate change mitigation and adaptation

Reference: pages 249, 258-263; progress pages 272-274; datapoints [E1-4-30] to [E1-4-34].

SBTi targets, validated and public since October 2024, covering ADP SA (the three Paris airports), base year 2019 (pages 259-260): Net Zero means "an absolute reduction in GHG emissions of 90% in 2050 compared with emissions in the reference year 2019, for Scopes 1, 2 and 3". Medium term: Scopes 1 and 2 -68% by 2030; "continuing to source 100% renewable electricity annually through to 2030"; Scope 3 -27.5% by 2030. Long term: Scopes 1 and 2 -90% between 2035 and 2050; Scope 3 -90% by 2050. Method: Absolute Contraction Approach, 2019 chosen as "the year when air transport emissions peaked".

ACA targets (pages 260-263): 22 of 26 airports are committed to ACA certification, eight at level 4 or 4+ and two at level 5. Seven have net-zero Scope 1-2 targets, for example Paris-CDG 1.5C, 2010 base of 153,002 tCO2eq, -90% by 2035; Paris-Orly 2010 base 35,299 tCO2eq, -90% by 2030.

"The establishment of a single overall greenhouse gas emissions reduction target, aligned with the regulatory scope, combining the individual targets for each airport, is currently in progress and planned for 2027" (page 258).

Adaptation (page 249): "In 2026, Groupe ADP plans to conduct a trial aimed at defining a vulnerability metric applicable to all new and existing projects."

Energy consumption and mix

Reference: pages 264-265; datapoints [E1-5-35] to [E1-5-43].

Total energy consumption 2025: 1,182,559 MWh, up 12% on 1,053,206 MWh (page 264).

Fossil share rose from 56% to 57%; renewable share fell from 44% to 43%; nuclear nil.

High climate impact sectors: 44 controlled assets and subsidiaries sit in NACE sections A-H and L, led by 25 in H52.23 air transport ground handling. Their energy consumption was 1,141,051 MWh on net revenue of EUR 5,688,544 thousand, an intensity of 0.20 MWh per thousand euros (2024: 0.19).

Method and limitation: 2025 used "actual data for assets for which consumption data are available (89% of the total energy consumption of these assets)" and "maintaining the proportions established in 2024" for the remaining 11% (page 265). Paris-CDG covered 13,270 MWh of natural gas with non-certified RED II biomethane guarantees of origin (page 264).

Gross Scopes 1, 2, 3 and total GHG emissions

Reference: pages 265-268; datapoints [E1-6-44] to [E1-6-55].

Group GHG assessment, tCO2eq (page 266):

Scope 1 emissions from regulated emission trading schemes fell from 43% to 35%. Scope 3 is dominated by category 11, use of sold products, at 16,030,663 tCO2eq for ADP SA alone (page 267). Total market-based emissions per net revenue were 3.80 tCO2eq per thousand euros (2024: 3.85). A country breakdown is given for France, Turkiye, Jordan, Tunisia, Macedonia, Georgia and Other (pages 267-268). Airports generate 98% of Group emissions (page 258).

Uncertainty (pages 218-219): for some airports "emissions are estimated by extrapolation, by applying a ratio of CO2eq emissions per passenger... based on those of Amman Airport (Jordan)"; those extrapolations "represent 4,800,292 tCO2eq of Scope 3 emissions... i.e. 19.0% of Groupe ADP's total Scope 3 emissions". The auditors raise this methodology in an emphasis of matter (page 435). The SBTi reporting boundary differs from the Group and ACA boundary, tabulated category by category (page 259).

GHG removals and mitigation projects financed through carbon credits

Reference: page 287; datapoints [E1-7-56] to [E1-7-61] and AR 56, AR 57, AR 59.

"Groupe ADP has already contributed 24,560 tonnes of CO2 to neutrality through the purchase of carbon credits for its 2024 GHG emissions. The Group plans to contribute a further 10,753 tonnes for its 2024 emissions. Groupe ADP expects to contribute around 36,000 tonnes for its GHG emissions in 2025" (page 287).

Credits planned for 2025 emissions: 36,003.

Quality (page 287): airports in the ACA programme apply the ACA Carbon Offset Requirements (Issue 2, June 2025), requiring certification by Gold Standard, VCS, Label Bas Carbone, Climate Action Reserve or American Carbon Registry and verification that reductions are real, additional, measurable, verifiable, permanent and unique. "Moreover, offset projects must not have negative externalities for local populations (i.e., Human Rights, etc.) or the environment (i.e., biodiversity, etc.)."

Internal carbon pricing

Reference: page 257; datapoints [E1-8-62] and [E1-8-63].

"The use of an internal carbon pricing system in the process of validating investment projects, from the upstream phase (feasibility studies and design), tends to encourage sobriety in terms of CO2 emissions during the construction and operating phases. Groupe ADP uses two complementary internal carbon pricing schemes" (page 257):

1. Shadow price. "Benchmark internal carbon price, known as the carbon shadow price: a carbon price defined by the company at EUR 100 per tonne of CO2eq is made available to project managers and can be incorporated into investment decisions. It is then applied to the greenhouse gas emissions generated during the operating phase by projects with a CapEx of more than EUR 3 million, so as to have a favourable impact on the economic indicators of projects with low CO2 emissions."

2. Carbon budget for projects. "Groupe ADP has also set itself the objective of defining a carbon budget (maximum volume of GHG emissions authorised in a complete cycle) for all investment projects with a CapEx of more than EUR 5 million. The emissions taken into account in this tool are those related to construction, maintenance or renovation, heating and cooling energy consumption, electricity consumption and the dismantling of decommissioned structures."

Policies related to pollution

Reference: air quality pages 290-291; water pages 294-295; datapoints [E2-1-12] to [E2-1-15].

Two material E2 matters are covered: limiting the impact on air quality and controlling water pollution (pages 288-289).

Air quality (page 290). "Groupe ADP's general policy consists of: work with local authorities to put in place an appropriate regulatory and standards framework... reduce pollutant emissions." The company is candid about a limit: "It should be noted here that decarbonisation does not systematically lead to a reduction in polluting emissions (as in the case of biomass boilers or biofuels, for example)."

Water (page 294). "The policy for managing the impact of airport activities on aquatic environments therefore consists of complying with the discharge thresholds imposed by local regulations." Prevention applies best available techniques: the three Paris airports "no longer use any plant protection products to manage their green spaces", de-icing products are biodegradable and comply with SAE AMS 1424 and 1428, and "To date, based on these databases (focused on Paris), ADP does not use any substances of concern in our airport processes."

Actions and resources related to pollution

Reference: air pages 291-293; water pages 295-298; datapoints [E2-2-16] to [E2-2-19].

"plugging networks, isolating pollution in specific basins, pumping and sending pumped products for treatment/destruction in special, approved branches, setting up floating booms". Measurements are made by COFRAC-accredited laboratories and published at www.entrevoisins.fr for the Paris airports.

Incidents in 2025 (pages 293, 295). Authorised non-compliant discharges occurred twice: "once at Paris-Charles de Gaulle, where the COD threshold was exceeded during the night of 11 to 12 December 2025 in the Seine river basin following the failure of the automatic discharge shut-off system", and "once at Paris-Orly, where an overflow due to a high water flow was observed between 24 January and 6 February 2025". For air, "at the Paris airports, several emission thresholds were exceeded during the year".

Resources (page 297): "The CapEx allocated for the implementation of these action plans amounts to EUR 10.4 million for 2026 for ADP SA."

Targets related to pollution

Reference: pages 291, 294; datapoints [E2-3-20] to [E2-3-25].

Groupe ADP sets no internal pollution targets and says so directly. On air quality: "Groupe ADP is subject to compliance with the regulatory thresholds imposed by local laws and regulations (orders, decrees, mandatory standards, etc.). As a result, the Group complies with these ambient air pollution targets and does not intend to develop specific internal standards and thresholds. However, the Group has a policy of anticipating regulatory constraints, enabling it to anticipate variations in the thresholds imposed and thus ensure compliance even in the event of regulatory changes... Moreover, the targets set and the way they are monitored (nature of monitoring, organisation, frequency) vary from country to country" (page 291).

On water: "The Group's facilities comply with the targets and thresholds imposed by the legislation to which they are subject", followed by named references including "Paris-Charles de Gaulle: Inter-prefectural decree No. 2020-12/DCSE/BPE/E of 17 September 2020" and "Paris-Orly: Inter-prefectural decree No. 2021 PREF/DCPPAT/BUPPE/282 of 28 December 2021", plus Almaty, Enfidha and Monastir, and Skopje. "The thresholds to be complied with described in each of these documents vary for each site and may vary according to the season... and/or the receiving environment" (page 294).

Pollution of air, water and soil

Reference: air page 293; water page 297; datapoints [E2-4-28] and [E2-4-30].

Air emissions 2025, kg/year, against CSRD disclosure thresholds (page 293): carbon monoxide 27,185 (threshold 500,000); ammonia 26 (10,000); nitrogen oxides 85,128 (100,000); sulphur oxides 3,861 (150,000); PAHs 11 (50); PM10 948 (50,000). "Groupe ADP's emissions into the air do not exceed any of the disclosure thresholds imposed by the CSRD. However, Groupe ADP voluntarily discloses its reporting data in the interests of transparency." Scope widened in 2025 from the Paris airports to seven airports, "covering 92% of the Group's scope of responsibility".

Water discharges 2025, kg/year, Paris airports (page 297): total nitrogen 391,974 (threshold 50,000); total phosphorus 35,595 (5,000); TOC 290,330 (50,000); trichloromethane 2,925 (10); zinc 996 (579); copper 677 (50); PAHs 410 (5); nickel 263 (20); chromium 213 (50); PCBs 207 (0.1); cyanides 65 (50); lead 52 (20).

A restatement is disclosed: "The 2024 results are the actual results (without estimates)... the estimates presented in last year's report overestimated the actual results measured by around 21%" (page 297). The auditors draw attention to the seven-airport air reporting scope (page 435). GHG emissions are reported under E1 and excluded here.

Transition plan on biodiversity and ecosystems

Reference: page 312; datapoints [E4-1-11] to [E4-1-15].

Groupe ADP discloses that it has no biodiversity transition plan yet and commits to a date. Under the heading "(Voluntary) Transition plan or indicate a timeframe for adoption (no later than 2027)": "THE TRANSITION PLAN WILL BE STRUCTURED ON THE BASIS OF THE RESULTS OF THE FINANCIAL QUANTIFICATION OF BIODIVERSITY RISKS AND WILL BE DEFINED AT THE SAME TIME AS THE RESILIENCE STRATEGY" (page 312, tagged [E4-1-15]).

On resilience of the strategy and business model, tagged [E4-1-11] to [E4-1-14]: "Groupe ADP is currently carrying out a study aimed at quantifying the risks to its financial business model associated with the loss of biodiversity. This study will help assess the potential impact on the Group's business model and define an appropriate resilience strategy." The matching target is "1 study to quantify biodiversity risks carried out" by 2027 (page 310).

Policies related to biodiversity and ecosystems

Reference: pages 308-310.

"In 2025, the Group renewed its ambition to preserve biodiversity by publishing its 2030 Biodiversity Commitments as part of the act4nature initiative" (page 308). "These commitments were defined on the basis of the materiality of the Group's Biodiversity Footprint and cover the Group's biodiversity impacts on its direct scope and its value chain (Scopes 1 and 3)." They were "validated by the act4nature international scientific committee, which includes EpE, IUCN, IDDRI and MEDEF" and "supported and signed at the highest level by the Chairman and CEO, Philippe Pascal" (page 309).

Alignment. "Groupe ADP's 2030 Biodiversity Commitments take into account 90% of the targets identified as relevant from the EU Strategy for 2030 and the Kunming-Montreal Global Biodiversity Framework" (page 308).

Structure (page 309). Four pillars - PROTECT key natural environments in line with ecological continuity; RESTORE space for biodiversity in urban environments; MOBILISE stakeholders in the airport community and beyond; ELEVATE biodiversity to a strategic level - broken into 20 commitments and 32 measurable, time-bound targets. "Groupe ADP's footprint measurement shows that 75% of its impacts are linked to land use for its property and infrastructure developments."

Actions and resources related to biodiversity and ecosystems

Reference: pages 310-312; datapoints [E4-3-25] to [E4-3-28].

2025 actions (pages 310-311). The Biodiversity Footprint study was updated and extended internationally, so "Groupe ADP now has a common reference year for its consolidated scope". Quantified actions:

• "The Paris airports are maintaining their target to preserve 25-30% of their surface area for biodiversity"; "47% of the grasslands at Paris-Charles de Gaulle airport are managed using late mowing and 28% at Paris-Orly".
• "The meadows at our three Paris airports are maintained without the use of plant protection products, a process that began in 2008."
• "Between 2023 and 2025, 74,000 sq.m. of land were restored at our airports... As a result, 24,000 sq.m. have been restored in France under this programme" (Nature 2050).
• "6,000 sq.m. of roofs were greened and three car parks were de-sealed."
• "four areas were placed under temporary protection during the nesting and breeding periods following the identification of a species of interest", with refuge areas trialled to limit collision risk.
• Orly's meadows are "the largest areas to receive" the Ecojardin label.

"In 2025, Groupe ADP had no recourse to any regulatory compensation projects" (page 307). Partners include the Ile-de-France Regional Biodiversity Agency, LPO-IDF and the Vegetal Local network; Queen Alia International Airport has partnered Jordan's RSCN since 2023.

Targets related to biodiversity and ecosystems

Reference: pages 303, 308, 310; datapoints [E4-4-29] to [E4-4-33].

The biodiversity policy "is broken down into 20 commitments and 32 targets that are measurable, time-bound and defined over time" (page 309); page 310 sets the key ones against the material impacts and risks.

Against "changes in land use and other nuisances associated with airport construction and operation":

• "1 map per relevant site of ecological corridors defined with the regions" - end-2028
• "100% of new developments/buildings incorporate a biodiversity approach, giving priority to nature-based solutions" - as of 2026
• "1 renaturalisation or habitat development project per site per year" - between 2026 and 2030
• "100% of new tenants and suppliers committed to a biodiversity approach" - as of 2027

Against "displacement and destruction of species linked to animal risk prevention activities for air traffic safety":

• "100% of animal risk prevention and green space management teams supported in implementing biodiversity-friendly actions" - continuous to 2030

Against "loss of ecosystem regulation services provided by nature":

• "1 biodiversity inventory per site, supplemented by annual observations" - by 2027
• "1 steering tool developed from 2026" and "1 study to quantify biodiversity risks carried out" - by 2027

Impact metrics related to biodiversity and ecosystems change

Reference: pages 303-306, 312; datapoints [E4-5-33] to [E4-5-41].

"The metric used to quantify Groupe ADP's impact on biodiversity is the MSA.km2 (Mean Species Abundance per km2) measured using the Global Biodiversity Score (GBS) methodology" (page 312), the GBS chosen "for its scientific robustness, based on the international EXIOBASE and GLOBIO models" (page 305).

Footprint (page 305): "Groupe ADP exerted pressure on biodiversity equivalent to the loss of 5,500 MSA.km2 in terrestrial environments and 23 MSA km2 in aquatic environments across all Scopes. Based on the pressures exerted in 2024, Groupe ADP's activities are estimated to have generated an additional footprint of 100 eq.km2 of ecosystems lost compared to the previous year." Soil sealing represents "90% of Groupe ADP's Scope 1 biodiversity impact" (page 237).

Sites near biodiversity-sensitive areas (pages 303-304): identified with IBAT for Key Biodiversity Areas and protected areas plus the IUCN Red List, with 8-13 km areas of influence. Overlap per site includes Paris-CDG 1 area / 4.21 km2; Paris-Orly 4 / 1.18 km2; Bodrum-Milas 2 / 197.68 km2; Almaty 2 / 11,739 km2.

Limitation stated (page 305): "The GBS tool has limitations in measuring the pressures associated with the direct destruction of species and the transport of exotic species."

Policies related to own workforce

Reference: pages 336-337, 341, 346, 352, 356; datapoints [S1-1-19] to [S1-1-24].

"In 2024, Groupe ADP formalised the framework of its Group HR policies, which had not previously existed: 2025-2029 Group HR Roadmap... It was approved in November 2024 by the Group's Chairman and Chief Executive Officer. In 2025, this HR Roadmap has been translated into charters for each area, validated in August 2025 by the Chairman and Chief Executive Officer" (page 336). Charters cover skills development, mobility and top management (page 337), diversity (page 341), health and safety (page 346) and quality of life at work (page 352). "They will be distributed in 2026 to employees within the consolidated scope."

Diversity Charter commitments (page 341): complying with and supplementing applicable regulations; "raising awareness among all employees, corporate officers and managers"; "promoting the application of the principle of non-discrimination in all its forms in all acts of management and decision-making"; promoting a representative workforce "at all levels of responsibility"; communicating commitments to employees and service providers; and "evaluating the effectiveness of the actions taken". "Groupe ADP condemns all forms of direct or indirect discrimination or harassment in the workplace."

Processes for engaging with own workforce and workers' representatives

Reference: pages 335-336, 341; datapoints [S1-2-25] to [S1-2-28].

"Groupe ADP implements a structured system of dialogue with its workforce in order to better understand the actual and potential impacts of its activities on employees. This dialogue focuses in particular on the subjects identified as material in the double materiality assessment: professions and skills, diversity and inclusion, health and safety at work and social dialogue" (page 335). "the Sustainability Report submitted under the CSRD was presented to ADP SA's Social and Economic Committee (SEC) for information and consultation in April 2025", and the SEC "is consulted every three years on strategic orientations, including measures linked to the ecological transition".

Channels (page 335): managerial dialogue with annual interviews; the SEC and its specialist committees, which "meets every week" at ADP SA; collective bargaining; and internal surveys, with a quality of life and working conditions survey "carried out every three years". Hub One runs "a weekly social barometer"; Hologarde relaunched a listening barometer in October 2025; Extime Duty Free Paris prepared an engagement survey at end-2025 for 2026 launch. "At TAV Airports... Although there is no trade union presence in Turkiye, formal collaboration with trade unions exists in certain countries (Tunisia, Kazakhstan)."

Processes to remediate negative impacts and channels to raise concerns

Reference: page 336, cross-referring to section 4.4.1.4 at pages 422-423; datapoints [S1-3-32] to [S1-3-34].

"The remedial measures and whistleblowing systems put in place by Groupe ADP are described in the section entitled '4.4.1.4 Whistleblowing system'" (page 336).

"The whistleblowing platform (https://alert.groupeadp.fr) was opened on 1 October 2018" and complies with the Sapin II, Potier and Waserman laws. "the whistleblowing system is accessible 24/7 to all Group employees, external and occasional employees, co-contractors as well as their respective subcontractors and suppliers, and more broadly to all stakeholders with an interest in acting under the duty of vigilance, via an outsourced and secure platform". "The whistleblowing charter has been translated into ten languages" (page 422).

Guarantees (page 422): "The Director of Ethics and Personal Data is responsible for handling reports and works directly under the Group's Chairman and Chief Executive Officer to ensure the independence of this process." A processing committee validates strategy, conclusions and recommendations collegially; "Throughout this process, the identity of the whistleblower is preserved. Acts of retaliation against the whistleblower may be punished... No sanctions have ever been imposed in this area."

Taking action on material impacts on own workforce

Reference: pages 337-340 (skills), 341-346 (diversity), 346-351 (health and safety); datapoints [S1-4-37] to [S1-4-43].

Skills (pages 337-339). At ADP SA: mapping of professions updated every two years "to target efforts on critical professions", and a Talent Marketplace for skills and succession planning. On the energy transition, "nearly 60 positions are directly dedicated to managing environmental and energy projects... It has recruited five employees for its Environment, Energy and CSR business lines by 2025", with "100 'Environment - Sustainable Development - ISO Standards - CSR' training courses in its catalogue" (page 338).

Diversity (pages 342-345). ADP SA works under the 7th 2023-2026 gender equality agreement of 18 July 2023, with compulsory manager training on "Preventing sexism in the workplace" and "Recruiting without discrimination"; on disability it has been committed "for almost 35 years, from the first collective agreement signed in 1991 to the 11th for the 2023-2026 period".

Health and safety (pages 349-351). "Since April 2025, all ADP SA employees have access to a full health check-up". Twelve entities hold ISO 45001 certification. Planned 2026 actions include a joint Safety Day, a Group OHS Committee, "securing 300 delivery bays" and 300 handling aids in baggage areas at Paris-CDG.

Targets related to own workforce

Reference: pages 331-332, 337, 342-345, 356.

Groupe ADP reports a nil return under each "Targets and key milestones" heading in the own workforce chapter, and states how effectiveness is tracked instead.

• Skills: "Groupe ADP plans to gradually introduce shared objectives by the end of this period. To date, no quantitative or qualitative targets have been set for all areas at Group level. The actions will be measured by the indicators presented in the section 'Actions taken, monitoring indicators and results' below. It will be reported to the Group Sharing Committee, whose first meeting was held on 11 April 2025" (page 337).
• Social dialogue: "There are no fixed targets set for social dialogue. The effectiveness of social dialogue is monitored in particular through the signing of agreements and employee surveys", and "There are no monitoring indicators at Group-level" (page 356).

Workforce involvement is addressed directly: "At this stage... the company workforce and their representatives have not been directly involved in setting objectives, monitoring associated performance or identifying improvements to be made" (page 337).

Caution: no S1-5 datapoint reference is printed; classified from the "Targets and key milestones" subsections themselves.

Characteristics of the undertaking's employees

Reference: pages 333-335; datapoint [S1-6-50].

Headcount at period end (page 333): total 30,333 (2024: 29,330, +3.4%); male 20,156 (19,366); female 10,177 (9,964); other and not disclosed nil.

By geography, countries with at least 50 employees (page 334): Turkiye 10,790; France 9,025; Kazakhstan 4,763; Georgia 1,517; Macedonia 1,025; Croatia 913; Tunisia 854; Jordan 463; United States 442 (up 689.3% from 56); Latvia 253; Spain 74 (down 81.0% from 390); Oman 63; Saudi Arabia 63; Italy 59; other 29.

By contract type: 26,056 permanent and 4,277 temporary in 2025 (page 345), against 27,391 permanent and 1,939 temporary in 2024 (page 334). "There are no employees with non-guaranteed working hours."

Scope (page 333): "The relative social metrics for ESRS S1 cover all Groupe ADP employees with a direct employment contract with a Group company, in all regions where the Group is present and in all Group activities and subsidiaries within the scope of financial consolidation: ADP SA, TAV Airports, Hub One, ADP International, including AIG (Jordan), Extime Duty Free Paris, Extime Travel Essentials Paris, Extime Media, Extime Campus, Hologarde, Paris Experience Group, Private Suite."

Collective bargaining coverage and social dialogue

Reference: page 356; datapoint [S1-8-60].

Coverage: "In total, 50.10% of employees are covered" by collective agreements (page 356). The metric is a banded table by country: collective bargaining coverage for EEA employees in countries with more than 50 employees representing more than 10% of total employees shows France in the 80-100% band, and for non-EEA employees Croatia in the 20-39% band, with Kazakhstan, Jordan and Tunisia also shown. Workplace representation (EEA only) is reported for France. For ADP SA the coverage "relates to the terms and conditions regarding the employee".

Two disclosures qualify the figure. A restatement: "In 2025, a new country will be covered: Croatia... Erratum: in 2024, Jordan and Tunisia were covered but not mentioned". And on the European dimension: "Groupe ADP is not affected by the European Works Council or the transnational consultation procedure, as it does not have a European subsidiary employing at least 150 employees."

Social dialogue is a material matter in its own right, presented as a positive impact - "High-quality social dialogue ensures a calmer working environment, strengthens trust between management and employees and prevents PSR" (page 332) - and "No negative impact has been identified, given the existence of social dialogue, which has been identified as a positive impact" (page 356).

Diversity metrics

Reference: pages 343, 345; datapoint [S1-9-66].

Gender (page 343): percentage of women 33.55%; percentage of women executives 35.78%; percentage of women recruited 39.74%.

Senior management (page 343):

The policy is monitored by "rate of women overall and of women executives" and "rate of recruitment of women", and those proportions "are monitored at the highest level by General Management and the Executive Committee".

Age distribution (page 345):

Diversity was added as a new material matter in 2025, as a positive impact on representation, and the report is explicit that "Diversity as covered by the IRO focuses on the subject of representation and is not related to gender pay equality" (page 341). No target is attached: "There are no fixed targets set at Group-level" (page 342). For the Board of ADP SA itself, female representation is 38.10% and independence 29.41% (page 221).

Social protection

Reference: pages 349-351.

"As part of its commitment to sustainability and in accordance with the CSRD, Groupe ADP ensures that all its consolidated subsidiaries benefit from social protection schemes aligned with local standards and/or the Group's internal policies. The entities covered by this valuation are ADP SA, TAV Airports, AIG, Merchant Aviation, Hub One, ADP International including SDA Croatia, Extime Media, Extime Relay, and Extime Duty Free Paris, Paris Experience Group, Private Suite" (page 349).

Coverage by category (pages 350-351), identical for 2024 and 2025:

The gap is identified: "99% of the Group's employees on permanent contracts (CDI) or fixed-term contracts (CDD) benefit from protection provided by local public programmes and/or benefits offered by the company against loss of income due to retirement. 1% is not covered: employees working in the following country: USA" (page 351).

The schemes are set "either on the basis of the national legislation in force, or based on internal policies where these offer better cover than local requirements" (page 349).

Caution: no S1-11 datapoint reference is printed; classified from the "Social protection" subsection and its coverage tables.

Persons with disabilities

Reference: pages 343-344; datapoints [S1-12-79] and [S1-12-80].

"In 2025, 2.5% of the Group's employees (760 people) were identified as disabled" (page 344).

By contract: 715 permanent and 39 fixed-term disabled workers, 2.74% and 0.91% respectively. "There are no fixed targets set at Group-level."

Actions (pages 343-344): ADP SA has been committed "for almost 35 years, from the first collective agreement signed in 1991 to the 11th for the 2023-2026 period", with a "Quality of life at work for people with disabilities" survey every two years run in December 2025 and Mission Handicap funding for equipment, workstation adjustments, LSF services and transport. Extime Duty Free Paris offers CESU Handicap vouchers of EUR 650 a year paid in full by the employer. Hub One has three trained disability advisors. TAV Airports gives employees with disabilities "more frequent health checks and more detailed monitoring than required by law". AIG has offered four one-year paid internships for disabled people since 2024.

Training and skills development metrics

Reference: page 340; datapoint [S1-13-83].

Performance and career development reviews, percentage of employees participating:

Average training hours per employee:

Proportion of employees trained (average workforce managed over the period): 91.2% to 97.7%, +6.6%.

Accounting policy: "Training metrics are calculated on the basis of the average number of employees managed over the period" (pages 335, 340). The figures diverge: review coverage and the proportion trained rose, but average training hours fell overall and fell 15.2% for women, reversing the 2024 position in which women received more hours than men.

Health and safety metrics

Reference: page 350; datapoint [S1-14-88].

"100% of the workforce is covered by a health management system" (page 350).

The deterioration is stated plainly: "In 2025, the frequency rate was 10.73 (9.80 in 2024)". One fatality occurred in 2025 against none in 2024. A gap is acknowledged: "The 'Number of work accidents without lost time' metric is being developed for 2026."

Twelve entities hold ISO 45001 certification: Paris-CDG, Paris-Orly, Paris-Le Bourget, AIG Amman, and for TAV Airports the terminals TAV Ege, TAV Ankara, TAV Milas Bodrum, FTA Antalya, TAV Macedonia, Almaty International Airport and the service companies BTA, ATU, TAV Technology, TAV OS and Havas. "Each company's internal audit includes a review of the occupational safety parameters, in accordance with Groupe ADP's 'Life Safety' key controls manual" (page 350).

Incidents, complaints and severe human rights impacts

Reference: page 346.

Discrimination incidents in 2025 (page 346):

The table appears under the heading "Discrimination incidents in 2025" immediately after the diversity and inclusion actions, and its third row reproduces the ESRS datapoint wording verbatim.

The whistleblowing platform handled 166 reports Group-wide in 2025, of which 64 were admissible, "an 81% increase in alerts received between 2024 and 2025" (page 422). No incidents of severe human rights impacts connected to the own workforce are reported, and no fines, penalties or compensation were payable.

Caution: no S1-17 datapoint reference is printed; classified from the "Discrimination incidents in 2025" table, whose row labels reproduce the S1-17 datapoints.

Policies related to value chain workers

Reference: pages 362, 365; datapoints [S2-1-14] to [S2-1-19].

"Groupe ADP has drawn up an Occupational Health and Safety Policy for the value chain, which is appended to its new Sustainable & Responsible Procurement Policy (version 2025), to be signed in 2026 by the Chief Financial Officers (CFOs) of the entities in the consolidated scope" (page 362). A companion policy on "Skills development and recruitment" in the value chain is likewise appended and "proposed for signature by the Chief Procurement Officers (CPOs)... in 2026" (page 365).

The operative instrument today is the Supplier & Partner CSR Charter, which "form[s] part of the contract and must be signed by the contract holders; these charters have been adapted locally and applied to all the Group's contracts > EUR 100k (and also those < EUR 100k for ADP SA) for several years... They include all the points of attention and vigilance to be exercised by contract holders within their own upstream value chain, in particular in favour of Human Rights, against forced labour, against child labour and against corruption" (page 362). Coverage differs by entity: "contract holders at a value of over EUR 100,000 with the subsidiary AIG; contracts holders identified by TAV Airports as having CSR risks; all contract holders for ADP SA and Hub One" (page 361). The new Group charter "will be distributed and published in Q1 2026".

Processes for engaging with value chain workers

Reference: page 361; datapoints [S2-2-20], [S2-2-21] and [S2-2-24].

Groupe ADP states the limit openly: "Generally speaking, there is no process set out for engagement with value chain workers. Groupe ADP is either subject to public procurement rules (ADP SA) or to the French Commercial Code... and does not work directly with value chain workers, as it cannot claim or take the risk of a subordinate relationship with them. This does not rule out occasional or systemic dialogue with some representatives, notably hierarchical managers, as part of its prevention, control or coordination prerogatives" (page 361).

The formal mechanisms made available to all upstream stakeholders, "including the mandated representatives of the employees of the companies contracting with the Group", are: "questionnaires including CSR criteria linked to the issues at stake in the consultations - with requests for evidence before the decision to award contracts"; "performance evaluation questionnaires... If the scores are below average, this results in written notification to the supplier"; "social audits - with associated progress plans, monitored during the performance of contracts"; "whistleblowing systems (ethics, work accidents... in application for ADP SA, planned from 2026 for TAV Airports)"; and "supplier meetings, depending on needs and issues, particularly in the social field".

Processes to remediate negative impacts and channels for value chain workers

Reference: page 362; datapoints [S2-3-26] to [S2-3-29].

"Groupe ADP provides all of its stakeholders in the value chain with a virtual ethical and social alert system, enabling the representatives of these stakeholders to issue any alert relating to their working conditions. If an alert is initiated, Groupe ADP's Ethics Department will follow up" (page 362). The system, already accessible to contract holders and their employees, "has since been referenced in the Supplier, Service Provider and Partner CSR Charter (2025 edition)". Matters recorded "include but are not limited to: occupational health and safety risk (with reference to its materiality); discrimination in the workplace; harassment in the workplace; infringement of the law or the French Labour Code."

On remedy: "Any repairs carried out comply with current legislation and the French Labour Code of the countries where Groupe ADP sources its purchasing... To date, the Group has not had to record any claims for compensation or reparation following the launch or confirmation of an alert following an investigation, whether arising from litigation or a lawsuit."

Taking action on material impacts on value chain workers

Reference: pages 363-366; datapoints [S2-4-30] to [S2-4-38].

Resources and systems at ADP SA (page 363): OHS risk criteria and questioning of candidates about their OHS policy; "preparation and implementation of more than 780 'prevention plans' for all contracts with operational implementation at airport sites"; "monitoring and collection - via appropriate real-time alert systems - of all information relating to accidents involving service providers... Four accidents were reported and documented by the centralised unit in 2025"; and "a central team dedicated to Sustainable & Responsible Purchasing (SRP) of 2.5 FTEs (three people)".

Embedding in purchasing (page 364): "The weighting of this CSR sub-criterion alone represents between 5% and 10% of the weighting of the overall score for the bids (including the economic, technical and CSR criteria)."

A named 2025 initiative (page 363): "the creation of the Airport Traffic Safety Collective (CSCA) at Paris-CDG airport in early 2025. The aim of this voluntary committee, which brings together 50 local companies, is to improve prevention and safety in traffic and manoeuvring areas."

Planned (page 364): on-site supplier audits outside France began - "The first two audits were carried out at two airport equipment suppliers in China and Taiwan in 2025, by the ADP SA CSR team."

Targets related to value chain workers

Reference: pages 358, 363, 365; datapoints [S2-5-39] to [S2-5-42].

Groupe ADP reports no CSRD targets for value chain workers and sets out what it monitors instead.

On health and safety, the IRO table states "No objectives have been set at this stage as regards the CSRD. Nevertheless, the group has a permanent commitment that translates into action (golden rule): 1 - prevent any serious accidents (with after-effects) or deaths; 2 - reduce accidents in the long term; 3 - offer personalised health and safety support to employees; 4 - manage our major OHS risks" (page 358). The disclosure adds: "The current metric concerns the number of workplace accidents at airports (accidents involving non-salaried Groupe ADP workers) reported to the Executive Committee via the alert system" (page 363). Four such accidents were reported in 2025.

On skills: "There are no targets or deadlines for the material matter of 'Securing skills and making jobs more attractive'... but there is a check on the resources allocated to vocational training, including the regulatory part and the specific skills of employees occupying certain jobs" (page 365).

Effectiveness is tracked through Supplier Performance Measurement campaigns and "social audits carried out in situ and on the premises of contract holders", on "a multi-year programme drawn up for a period of eight years" (page 365).

Policies related to affected communities

Reference: pages 374, 376; datapoints [S3-1-13], [S3-1-14], [S3-1-16], [S3-1-17].

Groupe ADP discloses a negative finding as its headline policy statement, twice. On noise: "An important change has occurred since the 2024 Sustainability Report: the CSRD analysis of the data points relating to policies has shown that the company does not have a formalised policy within the meaning of the MDR-P requirements. Groupe ADP is committed to minimising the noise pollution generated by its airport activities, in compliance with the applicable regulatory framework applicable in each of the countries in which it operates. The scope concerned is the consolidated scope excluding AIG" (page 374). The identical MDR-P finding is repeated for dialogue with the regions (page 376).

What stands in place of a formalised policy is the regulatory framework, named precisely: "Regulation (EU) No. 598/2014... on the establishment of rules and procedures with regard to the introduction of noise related operating restrictions at Union airports within a balanced approach" plus the French Environmental Code and Transport Code. Under Articles 26 and 37 of the decree of 20 July 2005, "ADP SA has been entrusted by the French State with the task of measuring the noise generated by aviation activity at its airfields", and it manages the home soundproofing aid scheme financed by the aviation noise tax (page 374).

Processes for engaging with affected communities

Reference: pages 371-373, 375; datapoints [S3-2-19] to [S3-2-24].

For ADP SA the long-standing channels are the Maisons de l'Environnement - the first created at Paris-CDG in 1995 (page 226) - the Entrevoisins website and the Environmental Consultation Committees chaired by the Prefect, together with the Advisory Committees for Assistance to Local Residents, "an offshoot of the environmental consultative committee, chaired by the Prefect, with representation from all three colleges (elected representatives, associations, local residents and professionals)" (page 375). Voluntary public consultations were held for Paris-Orly in 2024 and Paris-CDG in 2025: "These are designed to inform local residents and other local stakeholders about the Group's development projects. The conclusions of these consultations lead, if necessary, to changes in the project" (page 307).

For concession airports the report is explicit about the limits of control: "At airports where airside activities are not under the direct operational control of TAV Airports, the Group has no decision-making power over the sources of these impacts. In such cases, TAV Airports contributes, within the framework of its competences, to coordination, information sharing and dialogue with stakeholders, while the final responsibility for airside impacts lies with the authority or operator concerned" (page 373).

Processes to remediate negative impacts and channels for affected communities

Reference: page 373; datapoints [S3-3-27] and [S3-3-29].

"Groupe ADP has whistleblowing systems, presented in Section 4.4.1.4 Whistleblowing system, enabling affected communities to voice their concerns. These mechanisms are applied within each international subsidiary" (page 373).

Within ADP SA, "affected communities can voice their concerns or needs via: going to the Maisons de l'Environnement; the Entrevoisins website https:/entrevoisins.groupeadp.fr".

Within TAV Airports, "each airport in the network has an accessible complaints mechanism that allows relevant stakeholders to submit their concerns confidentially or anonymously through multiple channels adapted to the local context": meetings held according to community needs; "QR codes redirecting to the contact details of the Client Liaison Officer (CLO) are only available at Antalya and Almaty airports"; and an online complaints form on the TAV Airports website. "Claims are registered, assessed and processed within defined time limits, in accordance with the applicable procedures of the complaints mechanism. If necessary, independent external mechanisms also remain available for applicable claims."

Taking action on material impacts on affected communities

Reference: pages 374-376; datapoints [S3-4-30] to [S3-4-38].

Noise (pages 374-375). "For ADP SA, reducing emissions at source is a priority. The company implements a pricing system that encourages airlines to renew their aircraft fleets, and manages the noise abatement scheme for homes."

2025 results: "At Paris-Orly, the Prefect has issued an order prohibiting the noisiest aircraft of companies newly operating at Orly from landing or leaving the parking point for take-off between 10pm and 6am (with a cumulative noise margin of less than 17 EPNdB)." "In 2025, 1,480 new soundproofing applications were submitted to and accepted by the Advisory Committees for Assistance to Local Residents (ACLR), for a total of EUR 16.6 million in assistance." At Almaty, 132 detached houses were insulated in 2025 "with an average cost per house of KZT 4,008,659 (USD 7,687)".

Measurement and resources (pages 375-376). ADP SA operates ACNUSA-certified noise measurement stations; reference indicators are Lden and Ln, with French limits of 55 dB(A) Lden and 50 dB(A) Ln. "The laboratory employs around 60 people, including around five technical experts dedicated solely to noise measurement"; 25 people work at the Maison de l'Environnement et des Territoires; "Around 15 administrative, operational and technical experts" manage the soundproofing scheme.

Targets related to affected communities

Reference: pages 374-375, 377; datapoints [S3-5-39] to [S3-5-42].

Noise (page 374). "In line with CSRD requirements, no targets associated with this material matter have been revised, removed or replaced since last year's report. For ADP SA, the noise reduction target is defined within the framework of the environmental noise protection plans and the Impact Studies according to the Balanced Approach: reduce by a third the population affected by daytime noise at Paris-Charles de Gaulle and halve the population affected by night-time noise at Paris-Charles de Gaulle and Paris-Orly, based on the health indicators of Highly Annoyed (HA) and High Sleep Disturbance (HSD). It should be noted that the reference year and the year in which the target is reached are respectively for Paris-Orly (2018 and 2026) and Paris-Charles de Gaulle (2019 and 2030)."

Dialogue with the regions (page 377). A nil return with reasoning: "There are no fixed objectives other than the successful implementation of the actions. The aim is to maintain regular, ongoing dialogue. Measuring each exchange would make the systems more complex and could alter the quality of the dialogue."

Noise is therefore the one affected-communities matter carrying a quantified, dated target.

Policies related to consumers and end-users

Reference: pages 388-389, 393, 397-398; datapoints [S4-1-13] to [S4-1-17].

Three material S4 matters are covered: public and airport security and safety, service quality / hospitality for all, and airport access and multimodality (page 239).

Security and safety (pages 388-389). "Safety is the top priority in the civil aviation sector." End users covered are "passengers and their accompanying persons; staff working on the airports; local populations". "With regard to aeronautical safety, a risk map and a hazard identification register are drawn up for each airport and are monitored by dedicated governance bodies." For ADP SA, "a security programme and an airport safety management system for each of its hubs, which is submitted to the Civil Aviation Authority for information purposes... These policies are validated by each airport manager, who bears the highest responsibility in this area."

Hospitality for all (pages 397-398). Anchored in the 2020 corporate purpose, "To welcome passengers, operate and design airports, in a responsible manner and throughout the world", with two limbs - the Extime brand created in 2022 and universal accessibility: "Since 2008, ADP SA has been providing assistance to people with disabilities or reduced mobility at Paris airports. Over and above regulatory accessibility, ADP SA's guiding principle is to be a genuine player in inclusion and to meet the best global standards."

Processes for engaging with consumers and end-users

Reference: pages 386-387, 393, 396; datapoints [S4-2-18] to [S4-2-22].

ADP SA runs a "Customer Community", "now made up of 1,000 customers (French- and English-speaking)", used to "maintain a special relationship with travellers; listen to, understand and analyse their expectations; collect/test useful information in agile mode" (page 387). Quarterly surveys of departing passengers are carried out in the terminals on representative samples - "In 2024, Paris-Orly airport received 7,854 responses" - self-administered on tablets in seven languages (pages 393, 396).

Feedback is analysed from Google Reviews for both Paris hubs and for individual points of sale, with "replies to all comments posted on these same pages... currently being deployed"; from social networks, where "A dedicated team is also working on analysing information from social networks concerning Paris Airport"; and from complaints via the 3950 number and website form. Extime Duty Free Paris runs its own mystery-visit programme, OSCAR. "TAV Airports uses its new central CRM system... 19,000 comments were taken into account in 2024" (page 387).

Processes to remediate negative impacts and channels for consumers and end-users

Reference: page 388; datapoints [S4-3-23] to [S4-3-26].

"the Groupe ADP has whistleblowing systems, presented in Section 4.4.1.4 Whistleblowing system, enabling passengers to voice their concerns. These systems are applied within each international subsidiary. In the specific case of passenger complaints, feedback is mainly provided via each airport's website" (page 388).

ADP SA channels: "A dedicated telephone service: the 3950 number is accessible to all 24/7 for the chatbot and 7 days a week from 8a.m. to 8p.m. for advisers"; a freephone number for car park users; the online contact form on the Paris Aeroport and extime.com websites; the mobile application; social networks; and postal mail, with support in English and French.

Volumes, published with a one-year lag: "At the beginning of 2024, ADP SA estimated that in 2024 it handled 103.5 million passengers and 272,000 customer calls via the dedicated telephone line channel. Nearly 76,000 were discussed with the teams of telephone advisers. The customer teams handled a total of nearly 22,000 complaints from other communication channels." TAV Airports "handled more than 17,000 calls via its dedicated call centre. a clear increase (up 53% vs 2023)"; AIG "handled more than 10,000 calls... and ensured the management of 926 claims".

Taking action on material impacts on consumers and end-users

Reference: pages 390-391, 394-397; datapoints [S4-4-28] to [S4-4-37].

Security and safety (pages 390-391). In 2025 ADP SA "continued to deploy the European passenger and cabin baggage screening policy and the national roadmap, based on explosives detection systems (EDS Cabin Baggage) and body scanners at 1st level on the Paris hubs", and "has ordered around thirty additional EDS Cabin Baggage... By the end of 2027, up to 50% of departing passengers at Parisian airports will be screened by this new equipment."

Access and multimodality (pages 394-396). Four action plans run: parking, mobility, air-rail intermodality, and the joint ADP SA / Ile-de-France Mobilites plan launched in October 2023. Results: digital parking bookings 62%, "100% of target achieved"; "ACI ASQ rating: 3.94 in 2025, above the target of 3.85"; and "669 electric vehicle charging points in service by 2025. 67% of target achieved". "At Paris-Charles De Gaulle, the modal share of public transport will increase by 5% between 2023 and 2024, and at Paris-Orly by 3%."

CapEx (page 397): "The CapEx allocated for the implementation of these action plans amounts to EUR 43.1 million for 2026 for ADP SA." The auditors draw attention to this information and to the ADP SA-only CapEx scope (page 435).

Targets related to consumers and end-users

Reference: pages 389-390, 393-394, 396; datapoints [S4-5-38] to [S4-5-40].

Security and safety (pages 389-390). "Groupe ADP's airports share the objective of guaranteeing the highest level of safety and security in accordance with international, national and local regulations." The company discloses a confidentiality limit: "Furthermore, some internal targets are confidential and are part of each country's own safety and security management system."

Access and multimodality (pages 393-394). Quantified targets:

• "Target of a 29% increase in the modal share of public transport for Paris-Orly airport passengers between 2019 and 2035."
• "Target of a 27% increase in the modal share of public transport for Paris-Charles de Gaulle passengers between 2023 and 2050."
• "For parking: percentage use of digital technology in parking: >50% of bookings made online in 2025."
• "Number of electric vehicle charging stations (BRVE): target of 1,000 charging points by 2025."
• "Service quality: ACI ASQ rating >3.85 for car park quality."

Outcome is mixed: digital parking bookings reached 62% and the ASQ rating 3.94, both beating target, while charging points reached 669 of 1,000, "67% of target achieved" (page 396).

Business conduct policies and corporate culture

Reference: pages 409-411, 419-420; datapoints [G1-1-7] to [G1-1-11].

"Groupe ADP has developed an Ethics and Compliance Programme, based on a single code of conduct and procedures, but above all the deployment of a culture... the anti-corruption programme, incorporates the eight measures required by the Sapin II law" (page 410). Launched in 2018, it comprises the Ethics and Compliance Code of Conduct, a personal data protection policy and application charter, "an ethical charter governing the use of artificial intelligence", the Human Rights Policy and a whistleblowing report handling charter (page 409).

Governance (pages 410-411). The Ethics Department, created in 2018, became the Ethics and Personal Data Department in 2021 and was reorganised in 2023 into five divisions. "The Ethics and Personal Data Director reports directly to the Chairman and Chief Executive Officer to guarantee the independent handling of alerts."

Network and culture (pages 410, 419-420). "26 officers located in controlled subsidiaries... i.e., one for every 1,000 employees or so", 20 CARE coordinators. "88 ETHICAL COMMUNICATION INITIATIVES IN 2025". The annual Ethics Climate Barometer draws on "more than 5,000 (sample analysed by a polling institute to ensure representativeness)" respondents. Data protection is covered although it "did not emerge from the double materiality assessment as a material matter".

Prevention and detection of corruption and bribery

Reference: pages 409-413, 420; datapoints [G1-3-16] to [G1-3-21].

Regulatory framework named (page 411): the Sapin II law of 9 December 2016, the Potier law of 27 March 2017 on the duty of vigilance, and the Waserman law of 21 March 2022. "These regulations apply to subsidiaries and companies controlled directly and indirectly by Groupe ADP, as well as joint ventures and companies under joint control."

Risk mapping (page 411). "A specific risk mapping identifies potential corruption risk scenarios, as well as third parties and populations at risk. The last exercise was carried out in 2024 on all entities subject to the Sapin II law and already present in the Group. mapping exercises are carried out every three years, with the exception of newly integrated entities, for which the mapping exercise is carried out, as far as possible, within a year of their integration." The next mapping is due in 2027 (page 409).

Prevention system (page 409). An anti-corruption action plan per audited entity monitored annually; the ten procedures; "Assessment and monitoring of third parties (graduated due diligence depending on the level of risk assessed) and pre-acquisition audits"; and a control system of level 1 self-assessments, level 2 field testing, level 3 audit programme participation, an Ethics and Compliance control manual updated in 2025 and a "mock AFA questionnaire".

Targets related to business conduct

Renumbered rather than newly required: under the 2023 ESRS, business conduct targets fell under MDR-T. Groupe ADP's statement was prepared against the 2023 ESRS, so there is no section headed G1-3 Targets; the targets below are the ones the company states for its material business conduct matter.

Reference: page 409.

The G1 IRO table sets two measurable targets against the material matter "Prevention of ethics and compliance risks (including corruption)":

• "90% of the Group's employees have completed the general Ethics and Compliance e-learning module (Source: ENOCTA for TAV Airports, TALENSOFT for the rest)"
• "The whistleblowing system is effective and known to 82% of the Group's employees (Source: 2025 ethics barometer)"

Effectiveness is tracked alongside them: corruption risk mapping every three years, last done in 2024 and next in 2027; "Anti-corruption action plan for each audited entity, monitored annually"; a three-level control system with an Ethics and Compliance control manual updated in 2025 and a "mock AFA questionnaire"; and the annual Ethics Climate Barometer (pages 409, 420).

Planned 2026 objectives include "Strengthening the management of ethics and compliance action plans by acquiring a new tool" and "Updating the whistleblowing charter to give whistleblowers greater confidence in the process" (page 422).

Incidents of corruption or bribery

Reference: page 423; datapoints [G1-4-22] to [G1-4-26].

All corruption and bribery metrics are nil for 2025:

"No legal disputes concerning corruption or bribery were identified in 2025 for Groupe ADP or its employees" (page 423).

The nil return sits against a rising volume of reports overall: "In 2025, the Group handled 166 reports, 64 of which were deemed admissible: an 81% increase in alerts received between 2024 and 2025" (page 422). Of the 64, 42 came from internal sources, 12 were anonymous and 10 external or other; charts also break them down by Groupe ADP scope and by type of allegation, with footnotes stressing that a report is "Admissible report under legal requirements but not necessarily proven" and that the type is "selected from a drop-down list by the person submitting the report" (page 423).