Euronext ESG Policies and Statements

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Stéphane Boujnah

Message from Euronext CEO and Chairman of the Managing Board

With our unique federal model, Euronext is building the leading market infrastructure in Europe to shape capital markets for future generations.

Our mission is to connect European economies to global capital markets, to accelerate innovation and sustainable growth. In order to achieve these goals, we are committed to operating a sustainable global business for the benefit of all. 

We stand with our clients, team members, partners and all our stakeholders to ensure that our business practices and operations respect our environment, embrace diversity, value employee contribution, and respect basic human rights and appropriate rules for business ethics and professional conduct.

Because together, we shape capital markets for future generations.

Stéphane Boujnah

All the below policies and statements have been reviewed and approved by the Euronext Managing Board . The Managing Board conducts an annual review of the document, with the most recent review being conducted on 26 August 2024.

All Euronext Policies are reviewed by the Euronext Internal Audit department at least once every three years. The objectivity and organisational independence of the Internal Audit function are achieved through the Head of Internal Audit reporting directly to the Chairman of Euronext Audit Committee.

The document covers all companies controlled by Euronext N.V., directly or indirectly.

Euronext has zero tolerance for bribery and corruption. It will always forgo business practices rather than pay bribes and fully supports its employees in this regard. Euronext also expects its partners and vendors to adhere to anti-corruption standards and have appropriate controls in place.

Euronext considers as "bribery" or "corruption" any offering or receiving of an advantage, whether in cash or in kind, by Euronext or by an intermediary appointed by Euronext, and with a corrupt intent. It does not matter whether the bribe is actually successful; the corrupt act of offering or receiving a bribe can be sufficient to establish the offence. All facilitation payments are prohibited.

The policies described in the Euronext NV Code of Business Conduct and Ethics as well as our Anti-bribery and Anti-Fraud policies  serve to ensure compliance with applicable anti-corruption legislation.

Additionally, Euronext has established detailed procedures and monetary thresholds to govern the approval and declaration of gifts, business meals and business entertainment. Reports and requests for approval of gifts, business meals and business entertainment are managed and assessed by the independent Compliance function.

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In the geographies where Euronext conducts business activities, there are strict laws directed at preventing the use of the financial system for financial crimes, including money laundering, terrorist financing, violation of sanctions and bribery offences. Euronext is firmly committed to conducting business via its affiliates in full compliance with applicable anti-money laundering regulations in the countries where its affiliates operate, in order to prevent money laundering and terrorist financing, as well as any activity that facilitates money laundering or the funding of terrorist activities.

The Company is also firmly committed to conducting business in full compliance with all applicable sanctions laws, including but not limited to the Common and Foreign Security Policy (CFSP) of the European Union and the prohibitions and restrictions mandated by the sanctions programmes administered by the United States.

The Euronext Anti-Money Laundering and Terrorism Financing Policy provides the framework for the organisation and its employees to tackle these issues.

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Euronext is deeply committed to combatting modern slavery and human trafficking across all its Group entities. Upholding human rights principles and ensuring the dignity and equality of every individual is a core value for the organization. With its anti-slavery and human right policy and  supplier codes of conduct, Euronext shows its commitment to implementing and promoting practices that combat modern slavery in all its forms, as an employer, with its suppliers and as a financial market infrastructure.  See more in the policies below.

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Euronext Supplier Code of Conduct 2023

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Euronext has adopted a Code of Business Conduct and Ethics that reaffirms Euronext Group’s commitment to high standards of ethical conduct and reinforces our business ethics, policies and procedures. The Euronext NV Code of Business Conduct and Ethics serves as the foundation for the conduct expected of every board member and employee, including contractors, consultants and interns. The Policy is maintained by the Head of Compliance for the Group, and is endorsed by the Managing Board. The Code of Business Conduct and Ethics is reviewed every three years by Euronext’s Internal Audit Department, which is an independent function.

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Euronext N.V. Code of Business Conduct & Ethics

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jstein@euronext.com

Euronext has developed a comprehensive framework that addresses relevant organisational compliance risks, in line with the overall group governance which is organized based on the three lines of defense model. More details below.

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The federal governance model remains central to Euronext's organisation and naturally creates an environment where people of diverse cultures and backgrounds collaborate and drive the organisation forward. Diversity at Euronext includes gender, ethnicity, religion, sexual orientation, age, language, socioeconomic status, political orientation, physical ability, experience and education, and more broadly all forms of diversity. Diversity and Inclusion are embraced in every area of Euronext’s people agenda. Euronext is commitmed to strictly prohibit any diversity related type of discrimination in hiring, promotion, salaries and benefits and career evolution. See more in the below policy.

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Risk identifies the possibility that an unwanted event may occur, the consequences of which may be detrimental to staff, operations, business and objectives of the company and its reputation. Risk management seeks to identify, assess, and take corrective and/or mitigating actions when a risk is beyond Group risk appetite across the entirety of the Group’s activities and businesses.

Group Risk Management is supported by the Group Enterprise Risk Management Policy and the Group Risk Appetite Framework.  More details below for the framework and refer to Section 2.3 Control Framework of the Group Universal Registration Document for details on the Three Lines of Defense, Risk Process and Risk Appetite Framework

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Euronext is commitment to environmental sustainability, particularly in mitigating climate change and adapting to its impacts. Initiatives include renewable energy deployment, energy efficiency measures, and supply chain sustainability efforts. Additionally, the company is focused on climate-resilient infrastructure and ensuring business continuity during extreme weather events. Euronext integrates climate-related factors into its risk management approach and governance, following recommendations such as those from the Task Force on Climate-related Financial Disclosures (TCFD). The company fosters dialogue and awareness among its workforce on sustainability issues and incentivizes senior management's involvement in environmental matters.

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vubaldi@euronext.com

Euronext aims to create a fairer and more inclusive society. By leveraging its position in financing the real economy, Euronext provides businesses and individuals with access to capital and education. The policy promotes economic growth, employment, and financial empowerment. Euronext's commitment is supported by the Group Head of ESG and all relevant business lines.

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Euronext takes great importance in prioritizing health, safety, and employee well-being. The company maintains safe working environments and complies with health and safety laws and regulations. Euronext is dedicated to providing a work environment that promotes collaboration, performance, and innovation, living out the Group’s values of Unity, Agility, Energy, Integrity and Accountability. The company implements health and safety measures, including appointing and training personnel with special responsibilities, reporting accidents promptly, and monitoring absenteeism. Euronext also offers flexible working arrangements, including remote work options and flexible hours, while supporting care-giving employees and respecting parental leave in accordance with local regulations.

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Euronext, via its Whistleblowing Policy and Procedure, allows employees and third parties to report in confidence alleged breaches of the laws or Company policies, and protects anyone who reports in good faith, ensuring that they shall in no way be put at a disadvantage by the Company as a result of the report. The policy provides internal and external mechanisms to report unlawful and unethical behaviours. Employees participate in mandatory training sessions, primarily through Euronext’s e-learning platform and are informed of the mechanisms for reporting unlawful and unethical acts and behaviours.

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smachado@euron…

Euronext's performance and development policy focuses on fostering a performance culture, developing talent, and recognizing employee contributions. The company is committed to providing competitive and fair compensation, including variable components, to drive growth and sustainable performance. Euronext ensures that salaries are aligned with industry standards and local regulations, aiming to provide decent living wages. Decision-making processes for compensation are structured within the company's federal model, incorporating multiple levels of validation. Euronext promotes continuous feedback and conducts annual appraisal processes to address performance objectives, career opportunities, and training needs. Additionally, employees have access to share ownership programs to align their interests with the company's long-term goals. See more in the below policy. 

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Euronext is dedicated to protecting personal data and ensuring privacy in accordance with applicable data privacy laws, as outlined in our Personal Data Protection policy. The Group has established internal policies, procedures, and information notices to guide data processing activities. Training programs and awareness sessions are conducted regularly to promote compliance with data privacy laws and internal processes among employees. Euronext utilizes organizational and technical measures to safeguard personal data, such as IT tools for processing automation and risk assessment, Data Protection Impact Assessments, and the appointment of Business Data Owners. The Group implements monitoring programs to ensure GDPR compliance and monitors third-party companies processing data on its behalf. Reports are generated to address identified risks and inform relevant departments.

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Euronext recognizes the importance of maintaining integrity and trust in its markets and across the organization, including its procurement and supply chain. Suppliers play a crucial role in providing goods and services, and Euronext expects them to uphold the standards outlined in the Supplier Code of Conduct and Procurement and Supply Chain policy. These standards encompass compliance with laws, respect for human rights, prevention of forced labor and discrimination, and environmental responsibility. Euronext supports its suppliers in meeting these expectations and aims to have 72% of its suppliers with emissions covering purchased goods and services to set science-based targets by 2027. The company's procurement teams actively educate and support the supply chain in their ESG journey.

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Euronext Procurement and Supply Chain Policy

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Euronext is committed to offering responsible and sustainable product solutions that prioritize client needs and comply with regulations. Our product development process involves market research, impact and risk assessments, and conflict of interest mitigation. We actively support climate action and the transition to a 1.5° trajectory by expanding our range of ESG products. With a rigorous approval process and cross-department collaboration, we ensure high standards and strive for innovation and sustainable growth.

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Euronext's commitment to responsible marketing extends across all channels and events. This policy offers guidance to both employees and external partners involved in marketing and events for Euronext. It covers all marketing activities related to Euronext's products and services, as well as events organized by the company, across various departments and functions.

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Euronext values social dialogue and workers' representation rights, respecting collective bargaining and refraining from interference with union activities and is committed to International Labor Organization principles. Local works councils complement collective agreements, while a European-level social dialogue committee facilitates communication across the EEA. During significant organizational changes, Euronext engages in constructive dialogues with worker representatives, prioritizing measures to anticipate employment impacts and support affected employees.

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Euronext connects European economies to global capital markets, to accelerate innovation and sustainable growth. This commitment is underscored by its comprehensive Sustainability Policy, which outlines its governance, strategy, and initiatives aimed at integrating environmental, social, and governance (ESG) considerations into its operations and promoting sustainable finance.

 

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Euronext believes in actively participating in the public decision-making process while respecting the interests of stakeholders. In the Group’s Sustainable Lobbying policy, Euronext outlines the importance of providing clear and accurate information about the organization's lobbying activities, adhering to relevant laws, regulations, and codes of conduct related to lobbying and taking responsibility for the impact of lobbying activities on society and the environment.

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Euronext is dedicated to attracting and nurturing top talent to drive the Group’s strategic goals forward. Through strategic planning and recruitment partnerships, Euronext seeks to assemble a diverse and skilled workforce. The Group’s commitment to talent development, including international mobility and robust learning initiatives, empowers employees to grow and excel within our organization. Euronext prioritizes investing in its people, recognizing their pivotal role in the Group’s success.

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Euronext is a company that places great importance on adhering to regulatory compliance in its tax strategy. As a global organisation, it operates in various countries and territories and ensures compliance with relevant tax laws and regulations. 

Euronext’s Global Tax Policy describes the company's tax framework. The CFO, with support from the Group Finance Director, oversees the tax strategy and function. The company regularly engages with tax authorities to ensure adherence to relevant tax laws and regulations. Our tax function oversees our day to day responsibility for tax and ensures tax compliance. 

To ensure adherence to its regulatory framework, Euronext conducts periodic internal assessments and has established a whistleblowing policy to encourage reporting of any concerns

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Euronext is committed to a work environment in which all individual employees are treated with respect and dignity, as outlined in the Workplace Anti-Harassment Policy. Moreover, Section 2.9 of our Code of Business Conduct and Ethics aims to further clarify Euronext's position and commitment with respect to harassment in the workplace.

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