Adyen

The role of the administrative, management and supervisory bodies

Composition of administrative, management and supervisory bodies

Management Board

The Management Board comprises seven members as of 2024:

Changes in 2024: During the Extraordinary General Meeting of Shareholders on October 23, 2024, Tom Adams' proposed appointment as Chief Technology Officer (CTO) was approved. Alexander Matthey stepped down as Chief Technology Officer on October 23, 2024.

Supervisory Board

The Supervisory Board comprises six members:

Changes in 2024: During the Annual General Meeting of Shareholders on May 16, 2024, Adine Grate's proposed appointment as member of the Supervisory Board was approved.

Average age: 60 years
Average tenure: 5 years
Gender ratio: 50/50 (women/men)
Number of nationalities: 5

Diversity metrics

Supervisory Board diversity, competencies, and knowledge fields:

Independence

Throughout the year, five Supervisory Board members — Piero Overmars (Chair), Delfin Rueda, Pamela Joseph, Caoimhe Keogan, and Adine Grate — were independent.

Committees with sustainability oversight

Supervisory Board Committees

The Supervisory Board operates through specialized committees:

• Audit and Risk Committee (Chair: Delfin Rueda Arroyo): Supervises sustainability-related risks, such as anti-financial crime, business conduct, data privacy, and information security.

• Nomination and Remuneration Committee (Chair: Caoimhe Keogan): Oversees matters impacting employees, including company culture, diversity, equity, and inclusion (DEI), as well as learning & development (L&D).

The Committees' Terms of Reference demonstrate the relevant roles and responsibilities in relation to the material risks.

Management Board Committees

The Management Board is supported by:

• Risk Committee: Supports the Management Board with its oversight for the management of risk including sustainability risk, ensuring that risks are prudently managed in line with Adyen's risk appetite, regulatory requirements, and sound risk management practices.

• Integrity Risk Committee: Manages risks related to integrity matters.

To read more about the composition and role of the Risk Committee and Integrity Risk Committee, please refer to the Management Board Committees section of the Corporate Governance chapter.

ESG Working Group and Sustainability Impact Strategy Working Group

ESG Working Group (established in 2022): Focuses on the operational implementation of Adyen's ESG efforts. This cross-functional team includes members from the Reporting, Legal, Corporate Communications, and Procurement functions and works closely with subject-matter experts across the business. Primary responsibilities include:

• Tracking and driving progress for priority ESG topics and reporting initiatives
• Supporting the management of ESG-related risks and opportunities in alignment with Adyen's strategy
• Providing quarterly updates to the Management Board on ESG matters

The group has a direct reporting line to the CFO.

Sustainable Impact Strategy Working Group (formed in 2024): Focuses on driving and monitoring Adyen's Sustainable Impact Strategy. Comprising subject-matter experts from the strategy's core focus areas – Environmental sustainability, Impact technology, Social impact, and DEI. It is responsible for steering progress and providing strategic guidance in Adyen's strategic priorities for sustainability. It also has a direct reporting line to the CFO.

Both working groups collaborate closely, meet regularly to discuss their progress, and provide updates to the CFO on at least a quarterly basis.

Sustainability-related expertise and training

Adyen's governance bodies ensure appropriate skills are available to oversee sustainability matters through a combination of assessments, internal and external expertise, and ongoing education.

An assessment in 2024 evaluated the Management Board and Supervisory Board members' collective expertise, with particular focus on their knowledge and experience managing Adyen's identified impacts, risks, and opportunities. The assessment yielded clear examples demonstrating their experience and ability to effectively oversee the company's sustainability matters.

During the year, the Management Board and Supervisory Board also attended an external training session related to CSRD and its applicable reporting requirements. Both Boards value continuous education and deem it important to stay up-to-date on these matters, and therefore further training and education on material topics will be a key focus throughout 2025.

Where gaps exist in their knowledge or experience, these bodies leverage access to external and internal experts to complement their expertise with specialized knowledge and industry insights. By combining external knowledge with their direct expertise, both the Management Board and Supervisory Board are well-equipped to oversee sustainability matters and Adyen's reporting process.

The Management Board and Supervisory Board have gained experience and knowledge of sustainability topics material to Adyen through their current and previous executive- and non-executive positions. The members have gained this expertise, for example, through committee memberships, non-executive board positions, and internal and/or external trainings. The collective knowledge of the Management Board and Supervisory Board is deemed sufficient to fulfill their duties to manage and oversee impacts, risks, and opportunities to Adyen.

Frequency of sustainability discussions

Quarterly updates: On a quarterly basis, the ESG Working Group, with input from the Sustainable Impact Strategy Working Group and subject-matter experts across the business, is responsible for providing an overview of each of the identified material matters (in relation to their impact, risks, and opportunities) to the Management and Supervisory Board. The update, which summarizes target achievements, ongoing actions, and upcoming initiatives enables these bodies to assess Adyen's sustainability progress and make informed decisions on strategic adjustments and resource allocation. This overview is integrated into Adyen's regular reporting process to Management Board and Supervisory Board as part of a general business update.

Annual discussions: The company's overall ESG strategy and activities are discussed at the Supervisory Board level at least on an annual basis. In 2024, the material ESG matters were discussed at least once, and more frequently where deemed necessary, in the Supervisory Board and Committee meetings.

Ad-hoc reporting: Additional reporting on topics takes place as needed and as part of regular Management Board or Supervisory Board meetings (including the Audit and Risk Committee, and the Nomination and Remuneration Committee). The Management Board and Supervisory Board also discuss sustainability as part of the company's strategy in the annual strategy meeting.

Integration of sustainability into governance processes

By embedding ESG considerations and controls into standard internal audit and risk management protocols, Adyen ensures that ESG risks and impacts are managed consistently with other financial and operational risks, further integrating sustainability considerations into core operational functions.

The primary mechanism through which Adyen conducts due diligence is the Double Materiality Assessment (DMA). The outcome of the assessment is discussed with the Risk Committee and recommended for approval, approved by the Management Board, discussed by the Audit and Risk Committee, and then shared with the Supervisory Board. By assessing and delivering detailed insights on sustainability impacts, risks, and opportunities, the DMA process ensures the various management bodies are equipped to make decisions aligned with the sustainability interests and concerns of Adyen's key internal and external stakeholders.

Sustainability-related performance in incentive schemes

Adyen does not currently have any incentive schemes or remuneration policies linked to sustainability matters for members of its Management Board or Supervisory Board. For more information, please refer to the Remuneration report.

Integration of sustainability-related performance in incentive schemes

Disclosure statement

Adyen has not disclosed detailed information on the integration of sustainability-related performance in incentive schemes for the 2024 reporting period. While the company has established sustainability targets as part of its Sustainable Impact Strategy, specific linkage of these targets to remuneration for the CEO, Executive Committee, or broader management has not been substantively disclosed.

Reference to governance oversight

The Supervisory Board and its Committees closely oversee key sustainability matters. The Nomination and Remuneration Committee oversees matters impacting employees, including company culture, diversity, equity, and inclusion (DEI), as well as learning & development (L&D).

On a quarterly basis, the ESG Working Group, with input from the Sustainable Impact Strategy Working Group and subject-matter experts across the business, is responsible for providing an overview of each of the identified material matters (in relation to their impact, risks, and opportunities) to the Management and Supervisory Board. The update, which summarizes target achievements, ongoing actions, and upcoming initiatives enables these bodies to assess Adyen's sustainability progress and make informed decisions on strategic adjustments and resource allocation.

Sustainability targets in effect

Adyen has established the following sustainability targets as part of its Sustainable Impact Strategy:

However, the specific integration of these targets into executive or management incentive schemes (STI or LTI) has not been disclosed.

Strategy, business model and value chain

Business model

Adyen's single platform enables businesses around the world to deliver seamless payment experiences and innovative financial products to their consumers. Commercially structured across three core pillars — Digital, Unified Commerce, and Platforms — we focus on a fully integrated and in-house approach to ensure our customers benefit from the control, flexibility, and reliability that our platform offers. Our in-house approach also minimizes Adyen's exposure to sustainability risks, as our limited reliance on third parties results in a more streamlined value chain.

Products and services

The groups of products and services we currently offer include:

1. Settlement & processing services
2. Sale of POS terminals
3. Other services

For a breakdown of Adyen's revenue relating to the above-mentioned products and services, refer to Note 2 – Revenue and Segment reporting in the Consolidated Financial Statements.

Key inputs

To operate our business, we draw on a number of inputs, including our technical engineering and commercial expertise from Adyen employees, continuous customer feedback, licenses, software and hardware, data centers, transaction data, and payment terminals. Our approach to gathering these inputs entails rigorous risk management, adherence to regulatory standards, and continued investment in both our talented team and our technology.

Key outputs

As a result of these inputs, we offer our customers a flexible and reliable financial technology platform through a single integration. In addition, we ensure the security of sensitive information, protect privacy, and help detect and prevent fraud and other financial crimes with our secure IT platform.

Further to the advantages we offer our customers, we also directly benefit three other key stakeholder groups: investors, employees, and nonprofit organizations. As a publicly listed company, we provide financial returns to investors through publicly traded shares, delivering long-term value and financial growth. Our employees benefit from competitive financial compensation and the opportunity for professional growth and skill enhancement – fueled by our innovative culture. Additionally, nonprofit organizations benefit from donations made by consumers through Adyen's platform, enabling them to receive critical funding for the causes they support.

Value chain

Upstream value chain

Our upstream value chain consists of suppliers and vendors that support the smooth running of our platform. Our primary partnerships are with terminal providers, data centers, payment partners, distributors, and logistics providers. Within this, we prioritize working with global suppliers to ensure broad geographical availability as well as enhanced reliability.

While our reliance on third-party suppliers and vendors is minimal, our ability to fully assess and report on certain aspects of our value chain is currently limited by the availability of data from these entities. We are continually assessing options to enhance the accuracy of our value chain data as we evolve our reporting.

Downstream value chain

Our downstream value chain includes users of our products and services, as well as the customers that use our platform, covering sectors such as hospitality, food & beverage, retail, and e-commerce. Our customers include both business-to-business (B2B) and business-to-consumer (B2C) companies, each of which utilize Adyen's technology to tailor the payments experience to their unique needs.

Key markets and geographies

Adyen operates globally with a focus on providing payment services across multiple regions. The company serves customers in key sectors including hospitality, food & beverage, retail, and e-commerce.

Sustainability-related goals embedded in the business model

Our social impact philosophy is rooted in a simple yet powerful idea: that as our business expands, so too does our ability to drive meaningful change. Change is unlocked not only by utilizing our platform's technology to create a multiplier effect, but also by enabling our employees, partners, and communities to create lasting impact.

Social impact refers to the positive impact we seek to create through employee volunteering, nonprofit partnerships — including our Strategic Impact Partners — and our 1% Commitment. We believe our social impact initiatives can generate a positive impact and create a multiplier effect on people and the environment — particularly in the communities where we operate.

Our approach is geared toward making a positive impact across four key focus areas: Education, Emergency Response & Preparedness, Environmental Sustainability, and Local Communities.

As informed by our 2024 DMA, we believe our social impact initiatives can generate a positive impact and create a multiplier effect on people and the environment — particularly in the communities where we operate.

Interests and views of stakeholders

Identified key stakeholder groups

Adyen has identified the following key categories of stakeholders most relevant to the company:

• Employees (own workforce)
• Customers
• Investors and shareholders
• Nonprofit organizations (partners)
• Suppliers
• Regulators

Additional stakeholders referenced in specific contexts include:

• Value chain workers
• Affected communities
• Shoppers/consumers (end-users)

Stakeholder engagement methods and frequency

Employees

Engagement channels:

• Annual Culture & Inclusion (C&I) survey
• Employee Resource Groups (ERGs)
• Open feedback culture and direct conversations
• DEI Committees (regarding DEI strategies and programs)

Frequency: Annual survey; ongoing through feedback culture

How feedback is used: Feedback is gathered through the annual C&I survey and ERGs. The outcomes are reviewed by leadership teams and Management Board and taken into consideration during strategic discussions to refine Adyen's operational practices and sustainability approach. In 2024, 88% of Adyen employees responded to the C&I survey, representing a 2 percentage point increase from the 2023 baseline participation rate. Survey results are shared annually with leadership, whereas views from other channels are reviewed on an ad hoc basis.

Key concerns/views raised: The survey allows employees to share anonymized feedback at scale on workplace culture, helping identify areas of success and improvement that inform overall focus areas for the year.

Customers

Engagement channels:

• Regular meetings and events with leadership and commercial teams
• Net Promoter Score (NPS) surveys

Frequency: Regular/ongoing basis

How feedback is used: Adyen actively seeks customers' insights to assess how well products and services respond to customers' needs and priorities. Views are reviewed on an ad hoc basis to align with leadership's different touchpoints with customers throughout the year.

Shareholders and investors

Engagement channels:

• Annual General Meeting
• Quarterly earnings calls
• Regular investor meetings

Frequency: Annual AGM, quarterly earnings calls, regular meetings

How feedback is used: Stakeholders have the opportunity to engage directly with internal teams to provide input or ask questions on the company's financial performance and business developments.

Suppliers

Engagement channels:

• Onboarding process feedback
• Annual outreach during Double Materiality Assessment (DMA)

Frequency: During onboarding; annual DMA outreach

How feedback is used: Engagement occurs during onboarding and as part of annual outreach to address indirect emissions, leverage financial resources for decarbonization, and monitor emissions through annual greenhouse gas (GHG) inventory.

Nonprofit partners

Engagement channels:

• Regular engagement as part of impact approach

Frequency: Regular/ongoing

How feedback is used: Adyen regularly engages nonprofit partners to determine their most pressing needs and priorities, understand how to evolve the impact strategy, and shape impact products to deliver maximum benefits.

Regulators

Engagement channels:

• Formal meetings and communications
• Broader industry settings

Frequency: Regular basis through regulated activities; occasional broader settings

How feedback is used: Engagement occurs in regions where Adyen operates regulated activities.

Integration of stakeholder views into strategy and business model

The interests of stakeholders are central to Adyen's approach to building the business. By engaging with stakeholders, Adyen gathers insightful perspectives on strategy, better understands how stakeholders are impacted by Adyen, and establishes long-term relationships based on mutual trust.

Regular dialogue with stakeholders is critical to Adyen's ongoing due diligence process and sustainability materiality assessment. The company takes a holistic approach to identify key categories of stakeholders most relevant to the business.

The outcomes of stakeholder engagements are reviewed by leadership teams and the Management Board. They are taken into consideration during strategic discussions to refine Adyen's operational practices and sustainability approach where deemed necessary. The way stakeholder views are shared with leadership differs depending on the stakeholder group and the frequency and format of engagement.

Double Materiality Assessment (DMA) as key engagement mechanism:

Beyond more generalized stakeholder engagement through regular channels, Adyen gains a comprehensive understanding of stakeholder interests and perspectives relating to sustainability impacts, risks, and opportunities through the DMA process.

In preparation for CSRD requirements, Adyen refined and improved its DMA methodology in 2024 by performing a more thorough analysis, involving more external stakeholders and widening the scope across parts of the value chain.

DMA stakeholder engagement specifics:

As part of the 2024 assessment, Adyen engaged in direct stakeholder consultations to gain a comprehensive understanding of social and environmental impacts. The unique insights provided by these stakeholders—which included customers, investors, suppliers, and nonprofit partners, among others—offered a holistic perspective on Adyen's social and environmental impacts, helping identify risks that may affect long-term viability.

Internal experts were engaged to validate and challenge preliminary results, leveraging their subject-matter expertise and prior risk assessments. External stakeholders were engaged to get an outside-in view. Adyen's stakeholder engagement plan targeted diverse stakeholder groups to ensure a well-rounded assessment of material topics. The engagement approach was tailored for each group and mostly took place through in-person interviews or digital surveys.

Insights from stakeholder engagement focused on concerns, expectations, and perceptions of Adyen's impacts, risks, and opportunities. This process enriched Adyen's understanding of material issues and provided critical input for prioritization.

Following stakeholder engagement, the company combined its initial assessment with feedback and comments from stakeholders to form the outcome of the 2024 DMA. The outcome highlighted the top 10 material matters, forming the basis for Adyen's sustainability strategy and reporting for 2024.

The outcome was shared with the Risk Committee, who recommended it for approval to the Management Board. The DMA outcome was formally approved by the Management Board and shared for information with the Audit and Risk Committee and Supervisory Board.

How stakeholder views shaped the Sustainable Impact Strategy

To strengthen the commitment to sustainable growth, Adyen developed its Sustainable Impact Strategy in 2024, which sets out company-wide, long-term goals to enable prioritization of sustainable growth for people, the planet, and the product.

Adyen's DMA forms the basis of the Sustainable Impact Strategy, as the results offer a deeper understanding of the ESG matters most relevant to long-term sustainability and value creation. The annual DMA findings support building on the fundamentals of the license to operate and an environment where people are encouraged to speak up, maintain ethical standards, and embrace different perspectives.

Beyond this, to formulate targets, Adyen considered where it is uniquely positioned as a company to make a positive impact with its talented workforce, technology, and network. The process identified quantifiable targets against which progress can be continually measured.

As of 2024, these strategic priorities are reported internally on a quarterly basis to the Management Board and Supervisory Board to ensure sustained momentum and integrate these topics into the fabric of the business.

Distinction between affected stakeholders and users of sustainability information

The excerpts distinguish between:

Affected stakeholders (those impacted by the business):

• Employees (positively impacted by company culture, DEI initiatives, L&D programs)
• Customers (benefit from secure IT platform, flexible and reliable financial technology platform)
• Nonprofit organizations (benefit from donations made by consumers through Adyen's platform)
• Value chain workers (addressed through Supplier Code of Conduct)
• Shoppers/consumers (data privacy and security considerations)
• Communities (social impact programs)

Users of sustainability information:

• Investors and shareholders (provided with financial returns, engaged through AGM, quarterly earnings calls, and regular investor meetings)
• Regulators (engaged through formal meetings and communications)

The company explicitly notes that "management and key stakeholders across all regions have comprehensive insights into security performance, risks, and mitigation efforts."

Adyen recognizes that the DMA and double materiality processes may be subject to future changes, including processes for engaging with affected stakeholders. The Sustainability Statement may not include every impact, risk, opportunity, or additional entity-specific disclosure that each stakeholder considers important in its own assessment.

Engagement on specific material topics

Own Workforce topics:

For Company culture, DEI, and Learning & development, employees are considered the key stakeholder group affected. Thoughtful consideration is given to their interests when shaping and advocating for these initiatives. Adyen views its global team not only as representatives of the Formula but also its co-creators, iterating to reflect how employees feel the Formula should evolve along with the company.

For DEI specifically, Adyen engages employees through:

• Inclusion in the DEI approach through Employee Resource Groups
• DEI Committees (regarding DEI strategies and programs)
• Annual C&I survey
• Channels to raise concerns about discrimination

Data Privacy:

Stakeholders for data privacy include customers, end-users, suppliers, business partners, and other relevant data subjects. Individuals have the right to raise concerns or data privacy requests through an online form. Adyen has a process in place for ensuring that requests are addressed in a timely and effective manner.

Information Security:

Users of the Adyen platform, those working in Adyen environments (including all Adyen employees), and those affected by potential breaches (customers, shoppers, merchants, suppliers, regulators, employees) are key stakeholders.

Supplier engagement on sustainability:

In 2024, Adyen piloted its Supplier Code of Conduct, which extends Adyen's environmental responsibility across the value chain. The code stipulates that suppliers are expected to conduct responsible sourcing and exercise proper due diligence when providing materials to Adyen (or other customers) to ensure minimal environmental impact across procurement processes. It also requires suppliers to uphold social responsibility by respecting human rights and providing fair treatment.

Adyen engages suppliers throughout the year to address indirect emissions, leveraging financial resources for decarbonization and closely monitoring emissions through an annual greenhouse gas (GHG) inventory. For direct emissions, the company prioritizes working with global data center providers who use renewable energy to support climate transition goals.

The company has set a target that 80% of eligible suppliers (Scope 3 Categories 1, 2, 4, and 9) by spend have set their own science-based targets by 2028. As of 2024, progress stood at 18%.

Material impacts, risks and opportunities and their interaction with strategy and business model

Summary of Material IROs

Adyen's 2024 Double Materiality Assessment identified 10 material sustainability matters across environmental, social, and governance dimensions:

Interaction with Strategy and Business Model

Long-term value creation and sustainability integration:

Adyen's sustainability matters are integrated into strategy, business model, and decision making, which focus on enhancing workplace diversity and equality, upholding stringent ethical business practices, and reducing environmental footprint, among other priorities.

Adyen's long-term perspective remains fundamental to how the company builds its business. The company recognizes that neither Adyen nor its customers can thrive in an overstretched climate, so remain dedicated to honoring shared responsibility to protect the planet and its people.

Sustainable Impact Strategy:

Adyen developed its Sustainable Impact Strategy in 2024, leveraging the outcomes of the 2023 Double Materiality Assessment. This strategy sets out company-wide, long-term goals to enable prioritization of sustainable growth for people, the planet, and product across four sustainable impact priorities:

1. Diversity, Equity, and Inclusion (DEI)

   • Keeping DEI at our core and continuously embedding it throughout the organization
   • Building diverse leadership teams
   • Providing equal chance and equal pay

2. Social impact

   • Caring about giving back and multiplying our impact
   • Supporting organizations driving social and environmental change
   • Enabling access to community education

3. Environmental sustainability

   • Achieving key emission reductions in line with the Paris Agreement
   • Ensuring that suppliers uphold high ethical principles

4. Impact technology

   • Making impact the default for every transaction
   • Driving our network to generate donations at scale
   • Unlocking fundraising at scale for nonprofits
   • Responding to emergency appeals at speed

1% Commitment:

To make a sustainable impact not only within the company, but also throughout the world around it, Adyen has committed to contributing 1% of net revenue each year to causes that support the United Nations' Sustainable Development Goals (UN SDGs). This commitment, founded in 2022, is designed and invested to generate long-term positive change and to pair with technology, talent, and network to multiply reach. In 2024, this amount totaled €20.0 million.

Material IROs and Business Interaction

Own Workforce (Company culture, DEI, L&D):

As captured within the Adyen Formula, the more diverse the perspectives within the company, the sharper ideas become. A diversity of thoughts and experiences enables the company to continuously challenge and refine the products and services offered, and to make good decisions for customers, company, and the world at large. These unique and diverse perspectives consistently produce the most successful outcomes.

Working as one team across cultures and time zones is central to executing strategy. This cross-functional and cross-geographic approach ensures delivery of high level of service to global customers, and fosters strong collaboration between different functions, solutions, and pillars. This is further bolstered by the L&D approach, which focuses on equipping employees with the skills and knowledge needed to effectively execute on growth ambitions and deliver best-in-class products and services to customers.

Climate change:

Adyen prioritizes working with global data center providers who use renewable energy to support climate transition goals. For indirect emissions, the company engages suppliers throughout the year to address emissions, leveraging financial resources for decarbonization and closely monitoring emissions through an annual greenhouse gas (GHG) inventory.

In 2024, Adyen piloted its Supplier Code of Conduct, which extends environmental responsibility across the value chain. This code stipulates that suppliers are expected to conduct responsible sourcing and exercise proper due diligence when providing materials to ensure minimal environmental impact across procurement processes.

Information Security, Data Privacy, Anti-financial crime:

As a payment technology platform that works with some of the world's largest businesses, Adyen has inherently high-risk exposure to intrusion and disruption attacks. To counter this risk, Adyen has implemented an Information Security Program, which is continuously updated to address new threats.

Operating within the financial technology industry brings inherent exposure to criminal activity. Adyen therefore prioritizes anti-financial crime measures and has thoroughly integrated them into global ways of working. The goal is to build a future in which all financial transactions are secure, transparent, and trustworthy.

Resilience to Material IROs

Adyen considers its strategy and business model to be resilient and well-equipped to manage the identified risks while maximizing opportunities, ensuring sustainable growth over the long term. The company performs resilience analysis in the form of stress testing.

The 2024 DMA, conducted in alignment with the ESRS, reaffirmed the relevance of previously identified sustainability matters as part of the 2023 DMA. However, two new matters were identified: Company culture and Business conduct. Adyen has maintained strategic focus and initiatives without requiring substantial revisions to business model or operational strategies. This consistency reflects the stability and ongoing relevance of the risk and opportunity landscape.

Climate and Environmental risk assessment:

In 2023, Adyen conducted a comprehensive assessment of Climate & Environmental (C&E) risk. A thorough review of asset maturity, merchant base, and geographical exposures determined that Adyen has low residual risk exposure to both physical and transition risks. This is attributed to business model, operational risk management capabilities, and limited exposure to financed emissions, real estate, and other physical risks.

The assessment considered short- (1 year), medium- (3 years), and long-term (10 years) horizons, incorporating both qualitative and quantitative perspectives. For physical risk, the NGFS scenario "Current Policies" was applied over a 10-year forecast period. For transition risk, Adyen analyzed the impact of a high-transition-risk scenario, "Divergent Net Zero" from NGFS.

The findings showed that while scenarios had both positive and negative effects, the overall impact on Adyen's business strategy and model was limited. Overall, the analysis reaffirmed that Adyen's residual risk exposure to physical and transition risks remains low.

Description of the process to identify and assess material impacts, risks and opportunities

Double Materiality Assessment Methodology

Adyen's Double Materiality Assessment (DMA) is the process through which we collect and analyze stakeholder feedback to inform the selection of sustainability matters that Adyen deems material. In 2024, we refined and improved our methodology by performing a more thorough analysis, involving more external stakeholders and widening the scope across parts of the value chain.

Step 1: Understanding the business context by identifying stakeholders and reporting boundaries

The first step of our double materiality process was to map Adyen's value chain and its stakeholders to identify reporting boundaries. The primary aim of setting the reporting boundaries is to facilitate Adyen in assessing IROs relating to sustainability matters across our entire value chain, not limited to Adyen's own operations. To do this, we followed the latest ESRS guidelines and best practices, ensuring the assessment was comprehensive. Further, to specifically identify environmental boundaries, we leveraged the Locate, Evaluate, Assess, and Prepare (LEAP) approach. This process allowed us to map Adyen's entire business context and identify a full list of sustainability matters.

Step 2: Identifying potential sustainability matters

Having identified a long list of potential sustainability matters relevant to Adyen's operations and value chain, we ensured the list was complete by consulting other relevant sources. This included leveraging public sustainability standards, including those outlined in the ESRS, industry best practices, guidance from regulators, industry publications, existing Adyen disclosures, and our risk appetite statement. Moreover, we focused on Adyen's specific revenue streams and cost drivers alongside focusing on the possible sustainability matters relevant to the geographies in which Adyen operates.

We then proceeded to refine the long-list into a focused set of sustainability matters most relevant to Adyen by assessing the relevance and applicability of the long-listed topics together with internal stakeholders. The resulting short-list included only topics aligned with one or more ESG dimensions and deemed applicable to Adyen's business operating model. These prioritized topics served as the basis for subsequent stakeholder engagement and in depth assessment ensuring targeted and meaningful discussions.

Step 3: Assessing sustainability matters and engaging with stakeholders

Thresholds and scoring criteria:

In order to carry out the assessment, it was important to determine the thresholds and scoring criteria for Adyen to evaluate material sustainability matters. We aligned our methodology and thresholds with the principles outlined in ESRS.

Impact materiality: to assess the (potential) impact on people or the environment over short-, medium-, and long-term horizons relating to the sustainability matters identified as part of the short list, a severity criteria was established using scale, scope, irremediability (if negative in nature) and likelihood (if potential). In this assessment of the impact, we also took into account potential impacts on human rights, prioritizing any potential negative impacts.

Financial materiality: sustainability matters were also evaluated for their financial implications, including risks or opportunities affecting Adyen's performance, cash flow, or access to capital. Materiality was assessed in connection with a threshold based on a combination of the likelihood of occurrence and the potential magnitude of the financial effects. Matters assessed resulting in a score above a predefined threshold were classified as material. The same approach was also considered when assessing opportunities.

For scale, scope, irremediability, and likelihood, a five-point scale was developed to ensure uniformity between assessments. Matters that have either an impact, risk, or opportunity which received an average score higher than 2.4, are considered material for reporting purposes, as they have the potential to impact the Adyen's long-term strategy, influence stakeholder expectations, and are likely to become increasingly material in the future.

To conclude, a topic is designated as material if it creates a high level of impact on our stakeholders or the environment, or if it represents a significant risk or opportunity to Adyen that might materially affect our profitability, affect our strategy or both. When identifying material impacts, Adyen has also considered the risks and opportunities that may arise from those impacts. Similarly, when identifying risks and opportunities, dependencies are considered.

Stakeholder engagement:

Our DMA highlighted the importance of including the right stakeholders in qualitative discussions of the relevant matters at this stage. Internal experts were engaged to validate and challenge the preliminary results, leveraging their subject-matter expertise and prior risk assessments. Further, we recognized the value in engaging with external stakeholders to get an outside-in view. Adyen's stakeholder engagement plan targeted diverse stakeholder groups to ensure a well-rounded assessment of material topics. Our engagement approach was tailored for each group and mostly took place through in-person interviews or digital surveys.

Insights from stakeholder engagement focused on concerns, expectations, and perceptions of Adyen's impacts, risks, and opportunities. This process enriched Adyen's understanding of material issues and provided critical input for prioritization.

Step 4: Validating the outcome

Following the stakeholder engagement, we combined our initial assessment with the feedback, and comments from stakeholders to form the outcome of the 2024 DMA. The outcome highlighted the top 10 material matters, forming the basis for Adyen's sustainability strategy and reporting for 2024. As a final step, the outcome of the assessment was shared with the Risk Committee, who then recommended the outcome for approval to the Management Board. The outcome of the DMA was then formally approved by the Management Board and shared for information with the Audit and Risk Committee and Supervisory Board.

The DMA will be revised and reperformed on a regular basis as determined internally. At least on an annual basis, Adyen will assess and monitor if there have been any material changes to the business environment, development of new products and services, or changes in reporting boundaries that could impact the outcome of the DMA and re-assess accordingly.

Inputs to the Assessment

The DMA process utilized the following inputs:

• Sector benchmarks: Industry best practices and sector-specific considerations
• ESRS guidance: Latest ESRS guidelines and best practices, LEAP approach for environmental boundaries
• Internal experts: Subject-matter expertise and prior risk assessments from internal specialists
• External stakeholders: Customers, investors, suppliers, nonprofit partners, and other key stakeholder groups engaged through in-person interviews or digital surveys
• Regulatory guidance: Guidance from regulators in relevant jurisdictions
• Industry publications: Relevant industry publications and standards
• Existing Adyen disclosures: Internal documentation and previous reporting
• Risk appetite statement: Adyen's internal risk assessment framework

Materiality Threshold

Matters that have either an impact, risk, or opportunity which received an average score higher than 2.4 on a five-point scale are considered material for reporting purposes.

Time Horizons

For the purpose of the Sustainability Statement, Adyen applies the following definitions for:

• Short-term: 1 year
• Medium-term: 3 years
• Long-term: >5 years

Frequency and Last Review

The most recent comprehensive DMA was conducted in 2024. Previous assessments were carried out in 2022 and 2023. The DMA will be revised and reperformed on a regular basis as determined internally. At least on an annual basis, Adyen will assess and monitor if there have been any material changes that could impact the outcome of the DMA and re-assess accordingly.

Value Chain Mapping

Value chain mapping was a key component of the first step of the DMA process. Adyen mapped its entire value chain and stakeholders to identify reporting boundaries, ensuring that IROs relating to sustainability matters across the entire value chain were assessed, not limited to Adyen's own operations.

Material Impacts, Risks and Opportunities Identified

The 2024 DMA identified the following material sustainability matters:

Environmental IROs:

• Climate change (negative actual impact)

Social IROs:

• Company culture (risk and positive actual impact)
• DEI (positive actual impact)
• Learning & development (opportunity and positive actual impact)
• Social impact (positive potential impact)
• Impact technology (positive potential impact)

Governance IROs:

• Business conduct (risk)
• Information security (risk)
• Data privacy (risk)
• Anti-financial crime (risk)

Compared to the assessment performed and reported on in the 2023 Annual Report, this year's assessment led to the identification of two new sustainability matters being Company culture and Business conduct.

Integration with Risk Management

The DMA is leveraged as a targeted risk assessment and as a process to identify, assess and manage company wide impacts and risks. In particular, the assessment of financial materiality also feeds into our wider consideration of business risks as detailed further in the Risk Management section.

For climate and environmental related risks and opportunities, Adyen also leveraged insights from its Climate & Environmental (C&E) risk assessment.

Transition plan for climate change mitigation

Scope of the plan

Our climate transition plan is under development and therefore not currently in effect. The plan will build on the two initial targets that are in effect, covering Scope 2 emissions and Scope 3 supplier engagement.

Over the course of this year, our Workplace, Procurement, Supply Chain, and Infrastructure teams were identified as the primary teams working closely within our emissions hotspot areas and owning key supplier relationships where we have a high degree of dependency regarding our environmental data.

While our near-term Scope 2 target is in line with the Paris Agreement's 1.5 degree alignment pathway, because it commits us to full mitigation of our Scope 2 emissions by 2030, we recognize the need to take steps to mitigate our Scope 3 emissions over the longer-term to support the Paris Agreement's 2050 goals. Our supplier engagement target currently covers 48% of our Scope 3 emissions, based on our 2024 GHG inventory, and we are considering how best to tackle our remaining Scope 3 emissions as part of the transition plan development.

Business travel is another key source of Scope 3 emissions and one that we are monitoring closely, particularly as we continue to globalize and better understand what the steady-state of travel for our team will look like. We are also aware that potential future business expansion activities and customer commitments will need to be assessed and factored in to the extent possible.

Target year(s) for net zero / carbon neutral

We do not currently have any net-zero targets, but we fully recognize the importance of contributing to global efforts to achieve the goals laid out in the Paris Agreement.

While we do not yet have a specific timeline to share, in developing our transition plan, we aim to ensure alignment with the Paris Agreement while also integrating it with our broader business strategy.

Scope 1, 2, 3 reduction milestones with baseline years

Progress towards these time-bound goals is monitored using 2023 as our baseline year. As 2023 was our second year of comprehensive measurement, this baseline is considered representative of normal operating conditions, encompassing the larger headcount that resulted from our two-year period of accelerated investment in our global team — which concluded in 2023. Additionally, we do not yet have interim targets or milestones to share for either of the below targets.

Targets

Alignment with 1.5°C / SBTi validation status

In setting our Scope 2 target, we referred to the 1.5-degree scenario and considered the Science-Based Target initiative's (SBTi) framework to ensure our approach aligns with the goals of the Paris Agreement.

As noted above, our supplier engagement target currently covers 48% of our Scope 3 emissions, based on our 2024 GHG inventory, and is therefore not fully aligned with science-based reduction pathways (the Science-Based Targets Initiative recommends that supplier or customer engagement targets should collectively cover at least 67% of total Scope 3 emissions). We will therefore continue to consider how best to tackle our remaining Scope 3 emissions through the development of our transition plan.

Key levers / decarbonization pillars

The key elements of our approach in relation to climate change are:

• A commitment to quantifying, monitoring, and accounting for our environmental footprint.

• A key focus area is considering the impact of emissions for data center energy consumption, representing the largest portion of our combined purchased and acquired electricity and energy, and the hardware purchases that consume energy to power Adyen's platform.

• To minimize the carbon footprint of our infrastructure hardware procurement, we consider sustainable procurement guidelines that incorporate Life-Cycle Analysis (LCA) data, supplier emissions reduction targets, and ESG scores. Through these guidelines we aim to conduct an environmental impact assessment to better understand the carbon impact of our infrastructure activities, which tend to have higher carbon intensity, without compromising the performance or reliability of our infrastructure.

Specific actions taken in 2024:

Introducing environmental criteria in data center evaluation

During the year, we added a set of clear environmental criteria into our data center site selection process. By incorporating these criteria, we aim to assess how a new site might contribute to our Scope 2 target. We determine the carbon intensity of a site and whether it utilizes carbon-free energy sources or is matched with additional clean energy procurement, evaluate power usage efficiency (PUE), potential for carbon emission reductions, local community risk factors, and whether there are resource recovery features within the site design (for instance, heat recovery). We also conducted further analysis into our existing data center footprint to better understand how carbon intensity ranges across sites, and we evaluated other environmental metrics.

Evaluating our suppliers' sustainability journey

To capture opportunities and focus our supplier engagement efforts, we introduced an evaluation survey for our terminal hardware-related supply chain partners to help assess and determine where key suppliers are in terms of their own sustainability journeys. The survey responses will also inform where we prioritize our engagement efforts in 2025, with an expected pilot program focused on our terminal manufacturers. We recognize that working toward our 2028 target for 80% of suppliers (by spend) across Scope 3 Categories 1, 2, 4, and 9 to have set their own targets requires substantial preparation, availability of data, and internal expertise, all of which takes time to develop. To date, we have not identified specific amounts of carbon reduction linked to these actions.

Scope 2 clean energy target details:

Currently, Scope 2 emissions reflect Adyen's office locations and global data center locations. For the latter, clean energy procurement from our largest data center partner remains high and is reflected in our market-based emissions metric. As data center energy consumption continues to drive the majority of Adyen's total energy consumption — and is expected to increase further in the years ahead — our priority focus area will be to engage with key data center partners to prioritize carbon-free energy sources. Working with property owners of larger office locations to ensure clean energy sources are the default choice where available will also support this objective.

Transitioning to clean energy is a core requirement to meet the Paris Agreement's target of limiting global warming to 1.5°C and there is consensus among climate scientists that human activities, primarily the burning of fossil fuels, are the primary driver of climate change.

To monitor our performance towards this target, we assess market-based emissions data, which reflects the impact of purchased Renewable Energy Certificates (RECs). In full-year (FY) 2024, the portion included a total of 21,837 MWh in purchased RECs.

Scope 3 supplier engagement target details:

Carefully selecting the suppliers we work with allows us to take responsibility for both our own and our partners' environmental impacts. As mentioned, by collaborating with suppliers who share our vision, we can more effectively reduce these impacts, lessen our ecological footprint, and mitigate Adyen's climate transition risks in our supply chain.

The suppliers referred to in this target are those that form part of Adyen's indirect value chain. Specifically, this includes suppliers in Category 1 (Purchased Goods and Services), Category 2 (Capital Goods), Category 4 (Upstream Transportation and Distribution), and Category 9 (Downstream Transportation and Distribution), which together represent a significant portion of Adyen's total emissions footprint. To ensure effective decarbonization of this material portion of our Scope 3 emissions, we are targeting 80% supplier engagement by spend within these categories, which account for almost half of our total Scope 3 emissions in 2024.

In order to track this goal, we employ a rigorous methodology, assessing suppliers based on their own alignment with the SBTi (available in a public database) or core climate science criteria. We assume the accuracy of supplier data and their commitment to emissions reduction.

Our performance against this target is monitored by observing the percentage of spend with science-aligned suppliers across Scope 3 Categories 1, 2, 4, and 9 compared to total spend. In FY 2024, the portion increased by 5%, from 13% in 2023 to 18% in 2024.

Governance and accountability

To date, these two targets have not resulted in any changes to our business strategy.

The teams engaged in understanding our 2023 baseline environmental data and evaluating specific actions in order to operationalize our targets. In building accountability around execution, relevant Global Leadership Team (GLT) members were also made aware of key requirements expected from their respective functions and tasked with nominating individuals to own relevant data collection and strategy development within their team planning.

These climate-related targets were set by the Sustainable Impact Working Group with support from internal stakeholders. These internal inputs included support from the GLT together with feedback from the Management Board.

To ensure we remain on track for our targets, we actively monitor progress through a quarterly Management Report, which is also made available to our Supervisory Board.

Our CFO oversees the Sustainable Impact Working Group which is responsible for this approach, and upholds the responsibility of its decisions to the chairman of our Supervisory Board.

Policies related to climate change mitigation and adaptation

The Adyen way of building an ethical business

Adyen addresses climate change mitigation through its overarching ethical business framework titled "The Adyen way of building an ethical business".

Scope:

• Applies to whole global operations

Governance and accountability:

• The CFO oversees the Sustainable Impact Working Group which is responsible for this approach
• The CFO upholds the responsibility of decisions to the chairman of the Supervisory Board

Key content and principles:

• Commitment to quantifying, monitoring, and accounting for environmental footprint
• Key focus area on the impact of emissions for data center energy consumption, representing the largest portion of combined purchased and acquired electricity and energy, and hardware purchases that consume energy to power Adyen's platform
• Minimizing the carbon footprint of infrastructure hardware procurement through sustainable procurement guidelines that incorporate Life-Cycle Analysis (LCA) data, supplier emissions reduction targets, and ESG scores
• Conducting environmental impact assessment to better understand the carbon impact of infrastructure activities without compromising performance or reliability

Public availability:

• Available to external stakeholders via "The Adyen way of building an ethical business" document at investors.adyen.com/governance

Stakeholder engagement:

• Internal stakeholders were consulted while crafting the climate change approach

Targets related to climate change mitigation and adaptation

Adyen has set two near-term climate-related targets as part of its Sustainable Impact Strategy, with 2023 as the baseline year.

Target 1: Scope 2 Clean Energy

Target metric: Increase proportion of total Scope 2 clean energy consumption to 100%

Target year: 2030

Baseline year: 2023

Baseline value: Not explicitly disclosed

Progress (2024): 69%

Scope: Scope 2 emissions (office locations and global data center locations)

Target type: Absolute target (100% clean energy)

Validation: Near-term Scope 2 target is in line with the Paris Agreement's 1.5 degree alignment pathway. The company referred to the Science-Based Target initiative's (SBTi) framework to ensure alignment with Paris Agreement goals, though the target is not explicitly stated as SBTi-validated.

Details: The target reflects the proportion of market-based Scope 2 emissions relative to location-based Scope 2 emissions. The target includes the purchase of Renewable Energy Certificates (RECs), currently procured by data center partners on Adyen's behalf. In FY 2024, this included a total of 21,837 MWh in purchased RECs.

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Target 2: Supplier Engagement (Scope 3)

Target metric: 80% of eligible suppliers (Scope 3 Categories 1, 2, 4, and 9) by spend have set their own science-based targets

Target year: 2028

Baseline year: 2023

Baseline value: 13%

Progress (2024): 18%

Scope: Scope 3 Categories 1 (Purchased Goods and Services), 2 (Capital Goods), 4 (Upstream Transportation and Distribution), and 9 (Downstream Transportation and Distribution). These categories represent 48% of total Scope 3 emissions based on 2024 GHG inventory.

Target type: Supplier engagement target (not direct emissions reduction)

Validation: Target follows climate science criteria and SBTi alignment principles. However, the company acknowledges this target currently covers 48% of Scope 3 emissions, which is not fully aligned with SBTi recommendations (which require at least 67% coverage of total Scope 3 emissions).

Details: Suppliers are assessed based on their alignment with the SBTi or core climate science criteria. The company assumes the accuracy of supplier data and their commitment to emissions reduction.

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Additional Context

Transition plan status: While the company does not yet have a specific timeline to share, it is developing a comprehensive climate transition plan to ensure alignment with the Paris Agreement while integrating with broader business strategy. The company recognizes the need to take steps to mitigate Scope 3 emissions over the longer-term to support the Paris Agreement's 2050 goals.

Net-zero targets: The company does not currently have any net-zero targets, but fully recognizes the importance of contributing to global efforts to achieve the goals laid out in the Paris Agreement.

Interim targets: No interim targets or milestones have been shared for either of the two targets.

Monitoring: Progress towards time-bound goals is monitored using 2023 as the baseline year. Progress is actively monitored through a quarterly Management Report, which is also made available to the Supervisory Board.

Energy consumption and mix

Adyen disclosed energy consumption and mix data for 2024 in its CSRD-aligned Sustainability Statement (ESRS E1-5).

Total energy consumption and mix (2024)

Energy intensity

Scope and methodology:
Adyen's total energy consumption covers electricity and fuel across offices and data centers. The energy mix is derived by aggregating site-level consumption data, standardizing to kWh, and incorporating categorized regional and national grid electricity production mixes from credible sources such as EPA eGRID and IEA. Primary data sources include utility invoices and supplier energy consumption reports; where unavailable, regional grid factors are applied. The renewable energy figure reflects grid mix composition; renewable energy purchased via Renewable Energy Certificates (RECs) procured by data center partners on Adyen's behalf (21,837 MWh in 2024) is accounted for in Scope 2 market-based emissions rather than this energy mix breakdown.

Data center energy consumption accounts for the majority of Adyen's total energy consumption. Renewable energy coverage across global data center energy use remained high at over 98% in 2024 (based on RECs purchased on behalf of Adyen).

Phase-in and exclusions:
Adyen has availed of transitional provisions under ESRS 1 Appendix C. ESRS E1-5 paragraphs 38a, b, c, d, 39, and 40-43 are out of scope for this reporting year. The disclosure does not yet include all granular breakdowns required under the final ESRS E1-5 standard.

Gross Scopes 1, 2, 3 and Total GHG emissions

Gross Scopes 1, 2, 3 and total GHG emissions

Notes:

• Adyen does not participate in any regulated emission trading schemes.
• Market-based Scope 2 emissions are based on Renewable Energy Certificates purchased on behalf of Adyen to match data center energy use.
• Baseline year for targets is 2023.

GHG intensity based on net revenue

Scope 1 breakdown

Scope 1 emissions are derived from fugitive emissions and stationary combustion relating to office heating and cooling. In 2023, only refrigerant-based emissions in top 10 office locations were accounted for. In 2024, the scope was expanded to include stationary combustion alongside refrigerants across the full office footprint. Total Scope 1 emissions accounted for less than 1% of total emissions.

Scope 2 methodology

Scope 2 emissions account for electricity use across offices and data centers, as well as district heating. Calculated using both location-based and market-based methods. Location-based emissions reflect average emissions intensity of electricity grid where operations are located, unless supplier provides granular data. Market-based emissions reflect emissions reductions through purchased renewable energy for electricity, supported by contractual instruments such as Energy Attribute Certificates. Where contractual instruments or supplier-specific/residual mix factors unavailable, national average emission factors used. Primary data sources include invoices and local energy grid factors from EEA and US EPA. For smaller offices where primary data not readily available, assumptions and extrapolations based on headcount were used.

Scope 2 location-based emissions increased by 19% from 10,034 tCO₂e in 2023 to 11,966 tCO₂e in 2024 due to accounting for complete operational footprint and increases in energy consumption from office expansions and increase in data center sites and associated energy consumption. Scope 2 market-based emissions reflect Renewable Energy Certificates (RECs) purchased on Adyen's behalf.

Scope 3 methodology and breakdown

Scope 3 emissions result from activities across value chain. In 2024, total Scope 3 emissions increased by 10% from 2023, but remained nearly in line with prior year as proportion of total GHG emissions at 86%. In 2024, Category 3: Fuel and energy-related activities was accounted for in inventory. In 2023, Category 12: End of life treatment of sold products was accounted for (immaterial amount), however in 2024 sufficient data was not obtained from suppliers.

Given complex nature, Scope 3 emissions calculated using data from combination of sources, including supplier-reported, activity-based data and emissions factors derived from recognized databases. Where direct data unavailable, assumptions and approximations made. Adyen actively striving to refine assumptions by developing broader supplier engagement strategy and leveraging information to collaborate with suppliers in emissions hotspot areas.

Category 1: Purchased goods & services
Accounts for general goods and services procured by business and embedded emissions from manufacturing of physical IPP products. Includes all spend except capital goods spend and travel (included in other material Scope 3 categories). Direct spend matched with spend-based emissions factors from US EPA converted from USD to Euros. For hardware, LCA data leveraged covering majority of physical product offering. From 2023 to 2024, Category 1 emissions increased due to general spend and product sales.

Category 2: Capital goods
Accounts for hardware purchases for data center infrastructure. PCF reports from suppliers leveraged for majority of products. Where PCF reports unavailable, spend-based approach and EEIO factor applied. From 2023 to 2024, Category 2 emissions decreased due to procurement activities shifting towards less carbon-intensive products.

Category 6: Business travel
Accounts for emissions from business travel activities including flights, trains, hotels and car rentals. All travel emissions data generated through corporate travel booking system providing calculations in accordance with GHG Protocol. From 2023 to 2024, business travel-related emissions grew due to increase in Adyen team.

Category 11: Use of sold products
Accounts for lifetime energy consumption of physical products. In 2024, further engagement with hardware suppliers to obtain more granular data around energy consumption per device. With additional primary data, assessed lifetime energy consumption for average lifespan of 6 years by applying regional grid factor based on region of sales. Category 11 emissions increased from 2023 to 2024 but now reflect more detailed understanding of hardware products' energy use on per-device basis.

Category 3: Fuel- and energy-related activities
Includes emissions related to production of fuels and energy purchased and consumed. Accounted for by applying IEA factors to Scope 2 emissions.

Category 4: Upstream transportation
Accounts for shipping of physical products from suppliers to warehouses. Some suppliers provided activity-based data. Where unavailable, provided with granular shipment data and applied EPA emissions factors for ground and air shipments.

Category 9: Downstream transportation
Accounts for shipping activities from warehouses to customers. Similarly to Category 4, obtained combination of activity-based data and detailed shipment data.

Not material or not relevant categories:
Category 5 (Waste generated in operations), Category 8 (Upstream leased assets), Category 10 (Processing of sold products), Category 13 (Downstream leased assets), Category 14 (Franchises), Category 15 (Investments).

Internal carbon pricing

Internal carbon price set at EUR 92 per ton (referenced to UN Global Compact recommendation of USD 100 per ton), used as shadow fee to allocate funds for carbon removal initiatives. Determined contributions follow total Scope 1 and business travel emissions for each tCO₂eq emitted, multiplied by shadow price. Shadow price also leveraged by Infrastructure team to compare hardware models for carbon-intensive purchases.

Carbon removal contributions done on behalf of global entity. Total GHG emissions to be removed through Carbon Dioxide Removal (CDR) based on 2024 procurement are 4,757 tCO2eq from projects across US, UK and Singapore.

Biogenic emissions

Not separately disclosed.

Regulated emissions

Adyen does not participate in any regulated emission trading schemes (e.g. EU ETS).

Adyen's Contribution-Based Approach to Carbon Removal

At Adyen, we see an important place for carbon removal alongside efforts to reduce emissions in the transition to a more sustainable society. As a company, we are uniquely positioned to generate a relatively high profit per ton of emissions, enabling us to allocate resources to support the scaling of engineered solutions with the potential to achieve gigaton-level impact. Further, in line with our long-term view, we aim to be supportive of carbon removal projects, helping secure supply, scale innovative technologies, and maximize the range of co-benefits made possible through these programs.

Our contribution-based approach starts with an internal shadow carbon price, which allows us to establish a budget to allocate to carbon removal projects that capture and permanently store carbon dioxide. This price is based on guidance from the United Nations Global Compact as well as the latest Intergovernmental Panel on Climate Change (IPCC) report, which references this level as a benchmark for assessing the feasibility and cost-effectiveness of large-scale carbon removal efforts.

Through our partnership with ClimeFi, we continue to build a high-quality portfolio of carbon removal projects that align with our broader environmental sustainability goals and risk tolerance. Through our purchases, the companies we support generate credits representing verified tons of carbon dioxide removed from the atmosphere.

In 2024, we were especially proud to become the buyer of the world's first verified Enhanced Rock Weathering (ERW) carbon removal credits, provided by InPlanet, verified by Isometric, and facilitated by ClimeFi. This significant milestone builds on several years of purchasing credits for rock weathering and marks a significant step forward in the voluntary carbon market, introducing a high-quality, permanent carbon removal solution. ERW works by accelerating natural rock weathering and distributing crushed basalt onto agricultural fields in the tropics, ensuring durable carbon storage while also delivering economic benefits such as improved soil health, increased crop yields, and job creation. Unlike many other traditional carbon removal methods, such as forestation, ERW carries minimal risk of storage failure due to climate change, disease, or land use change. With its multitude of benefits, this solution represents another important step in our journey to support innovative and scientifically rigorous projects within our carbon removal portfolio.

Internal Carbon Pricing

Our contribution-based approach starts with an internal shadow carbon price, which allows us to establish a budget to allocate to carbon removal projects that capture and permanently store carbon dioxide. This price is based on guidance from the United Nations Global Compact as well as the latest Intergovernmental Panel on Climate Change (IPCC) report, which references this level as a benchmark for assessing the feasibility and cost-effectiveness of large-scale carbon removal efforts.

Policies related to own workforce

Adyen has disclosed several policies related to its own workforce under ESRS S1-1:

The Adyen Formula

• Policy name: The Adyen Formula
• Scope: All Adyen employees globally across all 28 offices
• Key content/principles: The Formula encompasses the distinctive way Adyen approaches work, including eight Formula points that guide actions and behaviors. It emphasizes diversity of perspectives, working as one team across cultures and time zones, and values including adaptability, speed, and simplicity. The Formula is central to how the company manages its business and drives success.
• Public availability: Available on Adyen's website with short videos explaining each of the eight Formula points. Also made generally available in physical offices and on the company intranet.
• Oversight: The Culture & Inclusion survey measuring culture is endorsed by the Management Board. In 2024, the Chief Risk and Compliance Officer (CRCO) acted as sponsor for the survey.
• Monitoring: Monitored through the annual Culture & Inclusion survey with 88% participation rate in 2024. Survey results are published on the company intranet and shared company-wide with accountability for the Global Leadership Team to implement focus areas.

Normal Course of Life Policy

• Policy name: Normal Course of Life
• Scope: All employees globally
• Key content/principles: Provides adaptability when navigating team members' life events, including starting a family or coping with difficult circumstances. Provides parental leave benefits to all employees in adherence with local legislation and/or collective bargaining agreements. Equal access to take leave is reflected in comparable percentages of women (12%) and men (10%) who took family-related leave in 2024.
• Monitoring: Tracks percentage of entitled employees that took family-related leave by gender (11% overall in 2024).

Diversity, Equity, and Inclusion Policy

• Policy name: Diversity, Equity, and Inclusion Policy
• Scope: The policy has been established in accordance with Best Practice Provision 2.1.5 of the Dutch Corporate Governance Code
• Oversight: Drawn up by the Supervisory Board
• Public availability: Available at Adyen's Governance webpage via investors.adyen.com/governance
• Key content/principles: Addresses diversity, equity and inclusion commitments and actions. DEI forms a key pillar of Adyen's Sustainable Impact Strategy with clearly defined goals, targets and metrics. The company believes diverse perspectives enable continuous challenge and refinement of products and services.
• Channels to raise concerns: Employees can raise concerns through Employee Resource Groups, DEI Committees, feedback culture mechanisms, and the annual Culture & Inclusion survey which allows voluntary and anonymous disclosure of under-represented group identification.
• Monitoring: Monitored through diversity metrics, equal pay audits, and the Culture & Inclusion survey responses which are compared across demographic groups.

Remuneration Policy

• Policy name: Global Remuneration Policy
• Scope: All employees globally, with specific policies for Management Board and Supervisory Board
• Key content/principles: Objective is to recruit and retain the best talent by offering competitive payment structures aligned with long-term ambitions. Benchmarks base salaries against tech industry standards by role, seniority level, and location. Ensures offers are above national minimum wage by country and aligned with collective bargaining agreements where applicable. Prioritizes fair and equitable remuneration.
• Oversight: Remuneration policies for Management Board and Supervisory Board received strong shareholder support at the AGM on May 11, 2023. The Nomination and Remuneration Committee oversees remuneration matters.
• International standards: Prepared in accordance with article 2:135 of the Dutch Civil Code, the Dutch Corporate Governance Code, Dutch Remuneration Policy for Financial Institutions Act, Rules on Sound Remuneration Policies, and EBA Guidelines on Sound Remuneration Policies.
• Monitoring: Tracks annual remuneration ratio (28 in 2024), adjusted and unadjusted pay gaps, and remuneration metrics by gender.

Learning & Development Approach

• Policy name: Learning & Development (L&D) approach (referenced as a policy under S1-1)
• Scope: All employees globally
• Key content/principles: Focuses on equipping employees with skills and knowledge needed to execute growth ambitions and deliver best-in-class products and services. Creates culture of autonomy and opportunities for growth. Encourages employees to drive their own development with unique career trajectories. Emphasizes continuous feedback.
• Monitoring: Employees receive ongoing training. In 2024, investments were made in scaling 'Feedback and Praise' programs and formally introducing upward feedback to support leadership growth.

Supplier Code of Conduct

• Policy name: Supplier Code of Conduct
• Scope: All suppliers across the value chain
• Key content/principles: Introduced in 2024 as an essential component of sustainability efforts. Addresses environmental responsibility beyond own operations, labor practices and human rights, health and safety, and ethics. Sets clear expectations for suppliers to ensure products and services are responsibly manufactured and sourced, minimizing waste, pollution and resource consumption throughout the value chain. Requires suppliers to conduct responsible sourcing and exercise proper due diligence, uphold social responsibility by respecting human rights, providing fair wages, ensuring non-discriminatory practices, and preventing forced or child labor, while also adhering to anti-corruption laws.
• Public availability: Available on the Adyen website
• International standards: Aligns with human rights frameworks
• Monitoring: In 2024, introduced an evaluation survey for key hardware supply chain partners to assess their sustainability journey, supporting the 2028 goal of having 80% of suppliers in key Scope 3 categories set their own emissions reduction targets.

The Adyen Way of Building an Ethical Business

• Policy name: The Adyen way of building an ethical business
• Scope: Encompasses approach across the organization
• Key content/principles: Adyen's overarching framework for ethical business conduct, which includes the approach to climate change, remuneration, and other workforce-related matters. Reflects commitment to making responsible, ethical decisions and considering long-term benefits for customers, Adyen, and the world at large.
• Public availability: Referenced in governance documents available on the governance webpage
• International standards: Aligned with the UN Guiding Principles on Business and Human Rights
• Monitoring: Implementation monitored through various mechanisms including the Double Materiality Assessment and stakeholder engagement processes.

Human Rights Approach

• Policy name: Respect for human rights (covered under Business Conduct)
• Key content/principles: Adyen's approach to human rights is embedded in business conduct policies. The company recognizes the importance of respecting human rights across its operations and value chain.
• International standards: Aligned with UN Guiding Principles on Business and Human Rights (UNGPs)
• Channels to raise concerns: Protection of whistleblowers mechanism and reporting channels for inappropriate behaviors
• Monitoring: Tracks incidents, complaints, and severe human rights impacts through S1-17 reporting

Note on policy scope: The disclosures provided apply to all employees in Adyen's workforce except where specifically stated. Adyen does not have explicit policies addressing trafficking in human beings, forced labor, compulsory labor, or child labor, as these are not considered material risks within the workforce. All Adyen employees and contingent workers are covered by health and safety management practices, in line with applicable local regulations.

Taking action on material impacts on own workforce

Adyen has implemented a range of DEI initiatives and actions spanning recruitment, development, and employee engagement. The company addresses material impacts on its workforce through three main pillars: DEI (Diversity, Equity and Inclusion), Company culture, and Learning & development.

DEI Actions (2024)

Recruitment and hiring initiatives:

• Providing equal opportunities for all Adyen employees to apply for roles at all levels by including both internal and external candidates in hiring processes
• Partnering with external organizations that support under-represented groups in tech
• Sponsoring and participating in several global events

Training and leadership development:

• Introducing training on inclusive leadership for leaders and HR Business Partners
• Requiring employees to complete the Ambassadors for Appropriate Behavior training as part of onboarding programs
• Conducting annual refresher training on reporting mechanisms for inappropriate behavior as part of annual compliance training
• Providing harassment prevention training in line with local regulatory requirements

Employee engagement mechanisms:

• Annual Culture & Inclusion (C&I) survey: Gathers anonymized feedback at scale to inform and refine global DEI initiatives, with insights used alongside focus group feedback, ERGs, and DEI Committees
• Employee Resource Groups (ERGs): 11 ERGs globally, employee-founded and led, voluntary and open to all employees. ERG Fair hosted during 2024 annual Connect week featuring booths for all 11 ERGs
• ERG executive sponsorship: Each ERG in the Americas has executive sponsorship by a member of the Global Leadership Team; rollout planned for EMEA and APAC in 2025
• DEI Committees: Provide input on DEI strategies and programs

Scope: All actions apply to own operations (global Adyen employees)

Time horizon: The document references 2024 implementation for the actions listed above. ERG sponsorship rollout for EMEA and APAC is planned for 2025 (short-term). The company emphasizes that DEI is "an ongoing journey with no finish line."

Resources allocated: No specific financial resources (capex/opex amounts) are disclosed for these actions. Non-financial resources include:

• HR Business Partners involved in inclusive leadership training
• Confidential Advisors available for Amsterdam-based employees
• Executive sponsorship from Global Leadership Team members for ERGs
• Employee time and engagement through ERGs (voluntary participation)

Expected outcomes/KPIs: Actions are linked to DEI Policy commitments around Equal Pay, Equal Chance, and Normal Course of Life. Effectiveness is measured through the annual C&I survey, which asks employees if they feel they can report unethical practices without fear of consequences.

Policy linkage: All actions support the DEI Policy (established December 2023 in accordance with Best Practice Provision 2.1.5 of the Dutch Corporate Governance Code) and the Inappropriate Behavior Policy.

Additional workforce actions referenced

The document references that Company culture and Learning & development also contain S1-4 actions, but specific details are stated to be in separate sections of the Sustainability Statement not included in these excerpts.

Targets related to own workforce

Adyen has set the following DEI-related targets for its own workforce:

Gender Diversity Targets

Progress to Date

• Supervisory Board: Currently meets the statutory requirement that no more than two-thirds identify as a single gender identity.
• Management Board: The current size and composition requires Adyen to set a longer time horizon to achieve this commitment.
• Hiring pipeline target: Data collection limitations in 2024 mean insights only represent a subset of applicants. Baseline will be established in 2025.

Additional Information

• Gender diversity targets align with EU Gender Balance Directive and Dutch statutory diversity targets (SER).
• Under-represented groups defined considering local communities, current demographics of specific functions, and consultation with Employee Resource Groups and DEI Program Managers.
• Equal Chance principle applied to hiring, internal moves, and total rewards.
• Hiring pipeline target depends on voluntary demographic survey participation in applicant tracking system.

Characteristics of the Undertaking's Employees

As of year-end 2024, Adyen employed 4,354 employees globally (4,345 FTEs), representing growth from our 2023 team.

Global Workforce Distribution

| North America | | | | | USA | San Francisco | 294 | 299 | | | New York | 207 | 186 | | | Chicago | 228 | 155 | | Canada | Toronto | 28 | 26 | | North America Total | | 757 | 666 |

| Asia-Pacific | | | | | Singapore | Singapore | 165 | 165 | | Australia | Sydney | 50 | 54 | | China | Shanghai | 49 | 36 | | | Hong Kong | 9 | 9 | | Japan | Tokyo | 40 | 33 | | India | Bengaluru | 26 | 0 | | | Mumbai | 11 | 12 | | Malaysia | Kuala Lumpur | 3 | 3 | | New Zealand | Auckland | 1 | 0 | | Asia-Pacific Total | | 354 | 312 |

| Latin America | | | | | Brazil | São Paulo | 175 | 171 | | | São José dos Campos | 56 | 39 | | Mexico | Mexico City | 29 | 27 | | Latin America Total | | 260 | 237 |

Total FTEs: 4,345 Total headcount: 4,354

In 2024, we welcomed 149 net new joiners during the year, which brought us to a total of 4,345 FTEs at the year's end. We opened a new Tech Hub in Bengaluru, India – which joins our existing Hubs in Chicago, Madrid, Amsterdam, and São José dos Campos – alongside our newly expanded office spaces in San Francisco, Madrid, Toronto, and São Paolo.

Across our 28 offices, our team is not only larger but also more diverse and dispersed than ever before. With 28 offices spanning 21 countries, we go to great lengths to preserve our unique ways of working as our team expands. Guided by the Adyen Formula, we foster a culture with speed and autonomy at its core, working across cultures and time zones to drive our business forward as one team.

Characteristics of non-employees in the undertaking's own workforce

Non-employee workers

Adyen's workforce is complemented by a small number of contingent workers who are engaged to help deliver on critical business needs.

Definition: Contingent workers are defined as workers who are employed by third-party services providers, or are self-employed, and provide services to Adyen on a temporary basis, including consultants, contractors, students (NextGens and temporary workers), and interns.

Metrics

Methodology: Headcount basis (not FTE). The number of contingent workers decreased year-over-year, which is in line with the decrease in contractor costs presented in Note 5 of the Financial Statements.

Coverage

All Adyen employees and contingent workers are covered by health and safety management practices, in line with applicable local regulations.

Breakdown by type

No detailed breakdown by type of non-employee worker (contractor vs agency worker vs self-employed vs students/interns) is provided in the disclosed metrics, though the definition indicates the population includes consultants, contractors, students (NextGens and temporary workers), and interns.

Collective bargaining coverage and social dialogue

Adyen's compensation approach ensures that offers are above the national minimum wage by country and are in line with Adyen's collective bargaining agreements, where applicable.

No quantitative data on the percentage of employees covered by collective bargaining agreements or workers' representatives is disclosed. No information is provided on the existence of a European Works Council or other social dialogue bodies.

Diversity metrics

Adyen reports diversity metrics covering gender and age distribution across management levels, including the Supervisory Board, Management Board, Global Leadership Team (GLT), Team Leads, and Individual Contributors.

Gender breakdown by management level

Age band distribution by management level

Global Leadership Team composition

Methodology notes

• Gender identity is self-disclosed by employees and captured in Adyen's HR Information System. For the Supervisory Board, it is maintained in an offline file.
• Age diversity is calculated based on date of birth captured during onboarding.
• Global Leadership Team (GLT) is defined as Adyen's 'top management' for ESRS S1-9 purposes.
• Management Board members must be approved by DNB (De Nederlandsche Bank).
• Total global headcount in 2024 was 4,354 employees.

Adequate wages

Adyen's disclosure on adequate wages (S1-10) is contained in the Remuneration Policy section of the Company culture sustainability statement.

Benchmark used: Adyen benchmarks base salaries against what other companies in the tech industry pay for the same role, at the same level of seniority, in the same location. The company states that compensation guidance "ensur[es] that our offer is above the national minimum wage by country and is in line with Adyen's collective bargaining agreements, where applicable."

Adyen explicitly states in footnote 30: "All Adyen employees are therefore paid an adequate wage, in line with ESRS S1-10."

Coverage: The statement applies to all Adyen employees globally (100% of own workforce).

Methodology:

• Benchmarking against tech industry compensation for same role, seniority, and location
• Ensuring compensation is above national minimum wage by country
• Compliance with collective bargaining agreements where applicable
• Annual audit to ensure equal pay standards

Geographic scope: Global - applies to all employees across all countries where Adyen operates.

Targets/commitments: No specific forward-looking targets disclosed beyond the ongoing commitment to maintain adequate wages.

Additional context: The remuneration policy objective is to "recruit and retain the best talent by offering competitive payment structures aligned with our long-term ambitions" and to "prioritize fair and equitable remuneration."

Social protection

Coverage of benefits ('The Essentials')

Adyen provides social protection benefits to all employees as part of 'The Essentials' - benefits applicable and relevant to all employees, plus those mandated by local governments. These form the foundation of Adyen's benefits system alongside equity models.

Regardless of office location, employee benefits include:

• Paid holidays
• Health insurance
• Disability insurance
• Commuting allowances
• In-office lunches

All practices are adapted by region to accommodate local practices.

Parental leave coverage

Adyen provides parental leave benefits to all employees in adherence with local legislation and/or collective bargaining agreements.

Excluding interns and part-time graduate program students. Percentages are calculated as a proportion of employees per gender, not total employees.

Additional benefits

Adyen+: A monthly stipend providing employees total autonomy and flexibility in how they spend contributions (e.g., childcare costs, language learning, or other interests and responsibilities).

Normal Course of Life policy: A distinctive benefit that accommodates diverse life experiences, supporting team members through extraordinary life events such as starting a family or coping with difficult circumstances. This policy approaches every employee's personal situation with nuance and understanding while providing universal benefits as standard.

Remuneration and pension

When calculating annual total remuneration, Adyen includes expected pension (please refer to the glossary for details on its estimation). The company conducts an annual assessment to estimate expected pension contributions, which are disclosed in Section 4.2 – Post-employment Benefit Obligations of the Financial Statements.

Training and skills development metrics

Performance and career development review coverage

Adyen tracks the percentage of employees participating in regular performance and career development reviews as part of its learning and development approach.

Methodology note: The performance of all employees is assessed as part of the Performance Review process and a performance rating is captured in Adyen's HR Information System. Employees who resign, are in the process of being terminated, or join Adyen during the performance review period may or may not receive a performance rating during that financial year. The Management Board undertakes a separate performance review process and is excluded from this metric.

Average training hours per employee

Adyen does not track average training hours per employee. The company states: "Regarding the individual growth of our employees, we believe each employee, in partnership with their manager, is best positioned to determine their unique development needs. For this reason, we don't track standardized metrics like the average number of training hours per employee, as we believe personalized growth paths are more valuable than company-wide metrics."

Total investment in training

Not disclosed.

Effectiveness measurement approach

Adyen assesses the effectiveness of its L&D approach through:

• Attendance data and survey feedback from classroom and e-learning sessions
• Facilitation effectiveness metrics
• Net Promoter Score (NPS)
• Annual Culture & Inclusion (C&I) survey to assess employee engagement
• Informal feedback from managers and focus groups

Health and safety metrics

Adyen states that all employees and contingent workers are covered by health and safety management practices, in line with applicable local regulations.

No specific health and safety metrics tables (fatalities, recordable work-related accidents, injury rates, or days lost) are disclosed in the excerpts provided.

Work-life balance metrics

Family-related leave

Adyen's 'Normal Course of Life' policy provides parental leave benefits to all employees in adherence with local legislation and/or collective bargaining agreements. The company reports comparable percentages of women and men who took family-related leave in 2024.

Methodology note: Percentages exclude interns and part-time graduate program students. Percentages are calculated as a proportion of employees per gender, not total employees.

Metrics not disclosed

• Percentage of employees entitled to family-related leave (by type: maternity/paternity/parental/family care)
• Return-to-work rate after parental leave (by gender)
• Multi-year comparisons

Compensation metrics

Pay gap

Adyen reports multiple pay gap metrics aligned with ESRS methodology:

Median adjusted pay gap: 3% (2024)

Average adjusted pay gap: 5% (2024)
This compares average annual base salaries for men and women in the same roles in the same locations, taking a weighted average.

Average unadjusted pay gap: 18% (2024)
This compares the average annual remuneration (including both fixed and variable compensation) of men and women, not taking into consideration any factors that could account for a pay gap between the genders, such as role and location.

Median unadjusted pay gap: 17% (2024)
This compares the median annual remuneration of men and women.

All pay gap calculations include all employees globally, including the Management Board and Global Leadership Team (excluding interns and part-time graduate program students).

Targets:

• Median adjusted pay gap <2% by 2028 (2024 progress: 3%)
• Zero unexplained cases of employee's salary deviating more than 5% from the salary guidance by 2028 (2024: 135 unexplained cases)

Remuneration ratio

Annual total remuneration ratio: 28:1 (2024)

This ratio compares the annual total remuneration of the highest paid individual to the median annual total remuneration for all employees (excluding the highest paid employee).

Total remuneration includes both fixed and variable compensation: base salary (based on 100% FTE), Adyen+, applicable allowances, expected pension, potential bonuses and commissions, Adyen Equity (calculated as fixed percentage of base salary), and sign-on equity (calculated based on value of the initial grant amount vesting over a period of 4 years). Benefits in-kind, which are not easily quantifiable, are excluded from remuneration calculations.

Methodology

Adjusted pay gap calculation: Takes into account factors that could explain potential pay differences, comparing the median annual base salary of men and women in the same role and location using a weighted average. Where a pay gap exists between men and women in the same role and location, this is multiplied by the number of employees in that team divided by the total number of employees where a pay gap exists. If no pay gap exists between men and women in the same role and location, or if there is only one gender represented per role and location, these employees are excluded from the calculation.

Unadjusted pay gap calculation: Compares annual remuneration without controlling for role, location, or other factors.

Remuneration ratio methodology: Follows ESRS methodology, comparing highest-paid individual to median employee total annual remuneration. This differs from the pay ratio outlined in the Remuneration report (7:1 for CEO, 10:1 for other Management Board members), which uses a different methodology required by the Dutch Corporate Governance Code and compares CEO's total fixed compensation to the average total fixed compensation of all Adyen employees globally.

Phase-in: Adyen voluntarily complies with CSRD/ESRS in 2024, in advance of the regulation being adopted into national law. This is Adyen's first year of ESRS reporting. 2024 is used as the baseline year for pay gap targets.

Incidents, complaints and severe human rights impacts

Adyen's S1-17 disclosure references grievance mechanisms and reporting channels for inappropriate behaviors in the Business Conduct section of the Sustainability Statement. The company states that employees have accessible channels for reporting grievances or related concerns, and refers readers to the DEI section for more information about how the company prevents and addresses discrimination.

However, no quantitative metrics are disclosed regarding:

• Number of incidents of discrimination or harassment
• Number of complaints filed through grievance mechanisms
• Number of severe human rights impacts
• Fines, penalties or compensation amounts
• Status of complaints (open/resolved/under investigation)

The excerpts indicate that ESRS S1-17 Paragraph 104 is explicitly noted as 'out of scope' in the disclosure index table.

Policies related to consumers and end-users

Adyen has disclosed policies relevant to consumers and end-users under ESRS S4-1, focusing on data privacy and anti-financial crime.

Privacy and Data Protection Policy

Policy name: Privacy and Data Protection Policy

Scope:

• Applies to the whole of Adyen in all countries where it operates
• Covers all Adyen employees, those working in Adyen environments, all computers, servers, and applications operating for Adyen's business purposes, users of the Adyen platform, and all other relevant data subjects

Key content and principles:

• Designed to ensure compliance with applicable data privacy and data protection laws worldwide
• Establishes restrictions and obligations on data usage
• Creates awareness and informs individuals about the processing of their data
• Includes obligations in case of a suspected data breach and Adyen's data breach notification obligations
• Prioritizes prevention, implementing data privacy protocols to minimize risks before they occur
• Includes safeguards to prevent unauthorized access to data

Governance and accountability:

• Follows the 'three lines of defense' model
• First line: Adyen employees encouraged to take individual responsibility for upholding data privacy
• Second line: Data Privacy Team, led by Adyen's Global Head of Data Privacy (who also serves as Data Protection Officer), responsible for driving compliance with applicable laws and regulations and ensuring data privacy practices align with latest industry best practices
• Responsibility for ensuring overall compliance sits with the Data Protection Officer
• Close collaboration with the Information Security Team

Public availability:

• Privacy and Data Protection Policy stored in internal documentation repository for easy access or reference
• Privacy Statement publicly available on the Adyen website

Alignment with international standards:

• Complies with GDPR in the European Union
• Complies with privacy and data protection laws in other countries, including state-level privacy laws in the United States
• SOC 2 standard compliance (audited by PwC)
• Complies with Adyen's wider incident reporting framework

Monitoring and implementation:

• Annual mandatory Data Privacy & Information Security training for all employees (begins at onboarding and refreshed annually)
• Educational materials continuously available on company intranet
• Training updated and enhanced in 2024
• Online form available for individuals to raise concerns or data privacy requests
• Process in place for ensuring requests are addressed in a timely and effective manner
• Incident response framework establishes mechanisms and processes to address data privacy events
• Tracks number of reportable data breaches
• Monitors training completion rates
• No quantitative targets set, but uses metrics as indicators of risk to ensure remaining within Adyen's risk appetite

Global Anti-Money Laundering, Counter-Financing of Terrorism, and Sanctions Policy

Policy name: Global Anti-Money Laundering, Counter-Financing of Terrorism, and Sanctions Policy

Scope:

• Applies to the whole Adyen group and in all countries where it operates

Key content and principles:

• Covers anti-money laundering (AML), counter-financing of terrorism (CFT), and sanctions
• Leverages advanced technology to conduct transaction monitoring to detect and respond to anomalous activities that may indicate money laundering or terrorism financing
• Sanctions compliance program ensures transactions and customers are screened against global sanctions lists
• Ensures full compliance with international regulations, including those issued by the United Nations, the European Union, and the United States Office of Foreign Assets Control (OFAC)

Governance and accountability:

• Follows the 'three lines of defense' model
• First line: operational management taking ownership and responsibility for managing risks
• Second line: oversight functions provided by Compliance and Risk, including second-line compliance, risk management, and model validation teams
• Application of technological systems overseen by second-line compliance, risk management, and model validation teams

Monitoring and implementation:

• Ongoing focus on employee training
• Regular, comprehensive AML/CFT and sanctions training programs provided to all employees

Related policies mentioned

Adyen also references the following related policies that support consumer and end-user protection:

• Privacy Statement
• Record Retention Policy
• Information Security Policy

Business Conduct Policies and Corporate Culture

The Adyen Formula

Fundamental to our environment is our unique culture, which we articulate through the 'Adyen Formula': a set of eight guiding principles that seek to align and inspire our team's attitudes, behaviors, and values. These core tenets, which help us maintain speed and autonomy as we grow, emphasize the value of seeking out different perspectives, pursuing constant iteration, and making good and ethical decisions with a long-term view in mind.

The eight principles of the Adyen Formula are:

1. We build to benefit all customers (not just one)
2. We make good decisions and consider the long-term benefits for our customers, Adyen, and the world at large
3. We launch fast and iterate
4. Winning is more important than ego; we work as a team across cultures and time zones
5. We don't hide behind email; instead we pick up the phone
6. We talk straight without being rude
7. We seek out different perspectives to sharpen our ideas
8. We create our own path to grow toward our full potential

Responsible Business Conduct

At Adyen, our long-term vision has been centered on building lasting relationships with our customers and innovating to meet their evolving needs. This intentional approach reaches beyond our core business to also respond to the trajectory of the world around us, recognizing sustainability as an important driver of our strategy for long-term value creation.

As a broad and multi-faceted topic encompassing environmental, social and governance (ESG) and ethical dimensions, sustainability demands that we thoughtfully integrate responsible practices across our business. This approach is written into our culture as one of the core principles of our Adyen Formula, which captures our commitment to making good decisions and considering the long-term benefits for our customers, company, and the world at large.

The Adyen Way of Building an Ethical Business

Throughout the year, we spent time reflecting this in The Adyen way of building an ethical business, a document outlining key policies and approaches across our business. The updated document will be published alongside this Annual Report.

For us, this holistic view of sustainable growth is fundamental to ensuring we support our customers and communities to succeed now and into the future.

Material Sustainability Topics

As a result of our Double Materiality Assessment (DMA), the material sustainability matters identified were: Climate change, Company culture, DEI, Learning & development (L&D), Social impact, Impact technology, Information security, Data privacy, Anti-financial crime, and Business conduct.

Diversity, Equity, and Inclusion

At Adyen, diversity, equity, and inclusion are central to our strategy and achieving our ambitions. We build our platform to benefit all customers and recognize that we can only do so successfully if our team reflects the diverse backgrounds and perspectives of our broad customer base.

Our DEI Policy is shaped by three core principles: • Equal Pay: Ensuring that employees with the same impact and in the same role receive the same pay. • Equal Chance: Providing equal opportunities for all employees, regardless of their background or identity. • Normal Course of Life: Supporting employees through significant life events with a flexible approach.

Our DEI Policy ultimately reflects our belief that diversity, equity, and inclusion are not just stated values, but living and breathing subjects to be explored and protected for long-term success. As part of this, we take every form of discriminatory attitude or harassment seriously, including micro-aggressions.

Management of Relationships with Suppliers

Supplier Code of Conduct

As a company committed to sustainability, it is important that we seek out and work with like-minded partners who share our commitment to reducing their impact on the climate and the environment. Adyen's Supplier Code of Conduct, which we introduced in 2024, is an essential component of our sustainability efforts as it addresses environmental responsibility beyond our own operations that may not be captured in emissions measurements.

By setting clear expectations for suppliers not only in terms of environmental performance, but also in additional areas such as labor practices and human rights, health and safety, and ethics, we help ensure that the products and services we purchase are responsibly manufactured and sourced, minimizing waste, pollution and resource consumption throughout the value chain.

Supplier Engagement on Sustainability

In 2024, we also introduced an evaluation survey for our key hardware supply chain partners to help them assess and determine where they are in their own sustainability journey. We see this as an important step toward our 2028 goal of having 80% of our suppliers in key Scope 3 categories set their own emissions reduction targets.

Data Center Supplier Management

In 2024, Adyen introduced a set of environmental criteria into our data center site selection process. These criteria help us to accurately determine whether a new site uses carbon-free energy sources and how a new site can contribute to our Scope 2 clean energy targets. This important step has helped ensure that our renewable energy coverage across our global data center energy use remained high at over 98% in 2024.

Sustainable Infrastructure Purchasing

Our infrastructure team follows internal guidelines for sustainable infrastructure purchasing to ensure sustainable and responsible decisions in this area.

Prevention and Detection of Corruption and Bribery

Operating within the financial technology industry brings with it inherent exposure to criminal activity; Adyen therefore prioritizes anti-financial crime measures and has thoroughly integrated them into our global ways of working. Our goal in doing so is to build a future in which all financial transactions are secure, transparent, and trustworthy.

Recognizing the profound impact that financial and economic crimes such as money laundering, terrorism financing, or sanctions violations can have on individual consumers and society at large, we have set in place a series of measures to prevent them.

Anti-Money Laundering, CFT, and Sanctions

Our approach to these risks is outlined within our internal Global Anti-Money Laundering, Counter Financing of Terrorism, and Sanctions Policy, which forms the basis of our efforts to prevent, identify, and report suspicious activities.

Key to our approach to anti-financial crime is our focus on equipping our global workforce with the means and training to combat financial crime concerns. As a bank and global financial institution, we find it essential that our team members play an active role in ensuring the safety of the landscape in which we operate. Our training programs therefore support our employees in the identification, reporting, and prevention of criminal activities, and we continue to improve and iterate our offerings whenever a better path is identified.

Another important aspect of our approach to anti-financial crime is how we leverage our technology to support our safety objectives. This includes a comprehensive transaction monitoring framework that is designed to detect and respond swiftly to suspicious activities.

Strengthening Our Approach

To strengthen our anti-financial crime framework and effectively address associated risks, we maintained a robust and proactive approach in 2024. One of the key actions that took place during the year was enhancing our Systematic Integrity Risk Analysis (SIRA), ensuring that Adyen continues to proactively identify and effectively mitigate integrity risks that may affect our business.

On an ongoing basis, Adyen also performs transaction filtering and monitoring, periodic or event-driven reviews of customers, and, where necessary, terminates business relationships that are beyond our risk appetite. This ensures Adyen maintains robust compliance, integrity, and operational resilience aligned with its risk appetite and regulatory obligations.

Incidents of corruption or bribery

Confirmed incidents and convictions

During 2024, there were no convictions or fines connected to violations of anti-corruption or bribery.

Disciplinary actions and contract terminations

Adyen has not disclosed specific numbers of employees dismissed or disciplined, or contracts with business partners terminated or not renewed, due to corruption or bribery in the reporting period.

Investigation procedures and speak-up mechanisms

Adyen has established multiple reporting channels and procedures designed to be promptly and independently activated based on the nature of the incident:

• Reporting channels: Employees and stakeholders can report suspected wrongdoing through a designated whistleblowing platform, directly to the Chairman of the Supervisory Board, or to an independent external whistleblowing body (Dutch Whistleblower Authority of the Dutch Central Bank).

• Investigation process: Reports are thoroughly reviewed following a four-eyes principle (requiring at least two individuals). Selected members of the second-line team are permitted to handle investigations, with defined timelines for each phase. Confirmed cases are reported to Adyen's Integrity Risk Committee on a quarterly basis.

• Safeguards: The Whistleblower Policy includes no-reprisal rights, confidentiality measures, and the option to report anonymously.

• Training and awareness: All employees are required to complete an annual Compliance Refresher Training covering anti-bribery and corruption, inappropriate behavior, whistleblowing, and conflicts of interest. Certain roles more exposed to bribery and corruption risks receive additional specialized training.

• Risk assessment: As part of the Systematic Integrity Risk Analysis (SIRA), Adyen performs periodic assessment of potential bribery and corruption risks during the course of doing business.

Policy effectiveness

Both Adyen's Anti-Bribery and Corruption policy and its underlying regulatory analysis are subject to annual review to ensure ongoing relevance and effectiveness. The policy is aligned with the United Nations Convention Against Corruption and provides comprehensive risk guidance for employees, customers, third parties, and partners.

Oversight of the ABC Policy rests with the Chief Risk and Compliance Officer (CRCO) and the wider Management Board. Outcomes are continuously monitored, with breaches and preventative actions documented and reported to the Management and Supervisory Board, as well as to the Integrity Risk Committee on a quarterly basis.