Effective date: April 18th, 2024

Approved by:

Michael KOMASINSKI, Chief Executive Manuela MONTAGNANA, Chief People Officer Ryan DAMON, Chief Legal and Officer Transformation Officer

Introduction

Criteo is committed to maintaining the highest standards of professional conduct and ethics while conducting its activities. This Policy applies to everyone at Criteo, i.e., to all Employees of Criteo S.A. and all of its subsidiaries and affiliates (collectively referred to as “Criteo”, “Group” or “Company”) regardless of position, location or level of responsibility as well as Criteo’s directors, temporary workers and interns (hereinafter “Employees”).

The Global Environmental Policy covers some of the main aspects of Criteo’s operations, from our infrastructure to the use of our products, and through the management of our offices, travel, and events.

As the Nomination and Corporate Governance Committee oversees, on behalf of the Board of Directors of Criteo S.A., the Company’s strategy on global corporate social responsibility (“CSR”) and environmental, social and governance (“ESG”), the Nomination and Corporate Governance Committee oversees this Policy and any procedures related thereto.

All Employees are expected to read and understand this Policy and conduct themselves in compliance with it. Any questions should be directed to the sustainability team at Sustainability@criteo.com.

Any changes made to the Global Environmental Policy will be communicated to Employees through the appropriate internal channels.

Table of Contents

KEY HIGHLIGHTS

PURPOSE

GOVERNANCE 6

OUR COMMITMENTS 7

RESPONSIBILITIES 8

ADMINISTRATION AND LEGAL COMPLIANCE

QUESTIONS

Key Highlights

100%

Criteo commits to continue active annual sourcing of 100% renewable electricity through 2030.

Criteo commits to reduce absolute scope 3 GHG emissions from purchased goods and services and business travel by 30% by 2030 from a 2022 base year.

Criteo commits to reduce absolute scope 1 greenhouse gas emissions by 42% by 2030 from a 2022 base year.

42%

We are developing an eco-design approach to reduce the impact of our products and solutions.

We ensure that our supply chain is sustainable by selecting our suppliers based on their EcoVadis score to the extent possible.

Purpose

At Criteo, we are committed to reducing our environmental footprint to create a sustainable future for everyone.

As a leading Advertising Technology company, paving the way for best-in-class sustainability standards in the industry is our responsibility and the only way forward to create a more promising future for all. At Criteo, sustainability means reimagining how we continue to develop our business while reducing our environmental footprint globally.

Sustainability is a core component of Criteo’s strategy, and our environmental obligations are at the heart of everything we do. This Policy, as well as our employee’s early commitments across the Company, now sit at the heart of all our teams, demonstrating our commitment to operate responsibly and drive positive change in the needs of our stakeholders.

• Embed sustainability into our governance and decision-making
• Leverage our products, solutions, and services to build a sustainably conscious future.
• Set reduction targets for our greenhouse gas (GHG) emissions, in line with the Paris Agreement.
• Contribute to global neutrality via projects to offset part of our residual GHG emissions.

Governance

The internal Sustainability Committee, which advises the internal Group Governance, Risk and Compliance Committee on the Company's goals, strategies, and commitments related to CSR and ESG matters, oversees and assesses the implementation of the Global Environmental Policy on an ongoing basis. The Sustainability Committee also reviews this Policy periodically.

The sustainability team under the supervision of the Chief People Officer, a member of the Leadership Team, is responsible for Criteo’s global environmental strategy, action plan and environmental management systems. The team carries out regular reviews with agencies and internal partners such as the infrastructure, procurement, IT, facilities, and finance teams, who provide support to the local teams.

Ultimate responsibility for climate risks and opportunities lies with the Chief Executive Officer of Criteo S.A. The Nomination and Corporate Governance Committee of the Board oversees the Company’s strategy on global CSR and ESG matters, and the Audit Committee of the Board oversees climate risks as part of its risk assessment and risk management responsibilities.

Our Commitments

Key Performance Indicators (“KPIs”) and targets are essential for monitoring progress and evaluating the effectiveness of environmental initiatives. This is why in 2023, following the publication of our first environmental roadmap, we set up targets to achieve by 2030, aligned with the 1.5°C scenario of the Paris Agreement. These targets have been set in line with the recommendations of the Science-Based Targets Initiative (SBTi), which validated them.

2030 targets approved by SBTi and aligned with the 1.5°C scenario (from a 2022 baseline year):

• Scope 1 - Criteo commits to reduce absolute scope 1 GHG emissions by 42% by 2030 from a 2022 base year.
• Scope 2 - Criteo commits to continue active annual sourcing of 100% renewable electricity through 2030.
• Scope 3 - Criteo further commits to reduce absolute scope 3 GHG emissions from purchased goods and services and business travel by 30% by 2030 from a 2022 base year.

Criteo’s Leadership Team, operational teams, and sustainability team worked in close collaboration to develop a thorough strategy, under the oversight of our Board. Our commitments are in line with recommendations from leading initiatives such as the Carbon Disclosure Project (CDP) and the Task Force on Climate-related Financial Disclosures (TCFD).

Each year, these KPIs will be audited by an independent third party as part of our annual non-financial performance statement included in our management report (our “CSR Report”), which also includes the results of our CSR risk mapping.

Responsibilities

This Policy outlines our commitment to environmental stewardship and sets forth our objectives and guidelines for conducting our business in an environmentally responsible manner. We strive to adopt industry best practices to minimize the impact of our operations on the environment. It serves as a guiding framework for all employees of Criteo, and we allocate the necessary resources to ensure its effective implementation and periodic review to remain relevant and aligned with evolving environmental challenges and best practices.

• Sustainable Products and Services: We integrate environmental considerations into the development, design, and delivery of our products and services.
• Supplier Engagement: We collaborate with our suppliers to promote sustainable practices throughout our supply chain.
• Employee Awareness and Engagement: We raise awareness among our employees about environmental issues and empower them to contribute to our sustainability goals.
• Continuous Improvement and Reporting: We regularly review our environmental performance and set targets for improvement.
• Environmental Management Systems: We establish and maintain effective environmental management systems to ensure the implementation of this Policy.

Administration and Legal Compliance

This Policy will be reviewed as required in the event of legislative changes, or changes to the Company. This Policy will be interpreted and applied in accordance with applicable laws, and to the extent this Policy conflicts with or is inconsistent with applicable laws, the applicable law will prevail over this Policy.

If you have any questions related to this Policy, please contact the sustainability team at Sustainability@criteo.com.