Our values, rules of conduct and behavior, as well as our guiding principles, are formalized in a Code of Ethics.

The main principles of this code are as follows:

• respect the integrity of the market;
• respect professional confidentiality;
• act with loyalty, competence, care, and diligence;
• prioritize clients’ interests and treat them fairly;
• identify, prevent as far as possible, and address any conflict of interest situations in the best interests of clients;
• carry out one’s activity independently, transparently, and in compliance with the principle of separation of duties and functions.

By sharing this Code of Ethics, the Group affirms its intention to guarantee the sustainability of its business model for its shareholders; and for its employees and commercial partners, pride and confidence in their professional environment.

This code is supplemented by ethical charters and policies, which are published (below) so that the Group’s partners who wish to do so may consult and refer to them. Internal control and risk management procedures are also detailed in the management report, in order to ensure transparency and a clear dissemination of the Group’s expectations regarding ethics and compliance. The Group remains available to its partners to discuss these matters and provide the necessary resources to ensure proper understanding and application of these principles.

Through the publication of these documents, the Group reaffirms its intention to guarantee the sustainability of its business model for its shareholders; and for its employees and commercial partners, pride and confidence in their professional environment.

The Gender Equality Index is calculated based on the results obtained for the four following indicators:

• Pay gap: 27/40
• Difference in the rate of individual increases and promotions: 35/35
• Return from maternity leave: 15/15
• Gender under-representation among the 10 highest earners: 0/10

Among the four indicators, two did not achieve the maximum score:

Indicator related to the pay gap

Progress objective: As part of its 2026–2028 Gender Equality Policy, ABC Arbitrage is committed to implementing an action plan to increase gender diversity in professions currently underrepresented by women, particularly trading and IT development. The goal is to increase the proportion of women recruited for these higher-paying roles by the end of 2028 through several targeted initiatives, including: partnerships with committed recruitment agencies, participation in specialized forums, presentations in schools, postings on relevant job boards, auditing and improving the recruitment process, raising recruiters’ awareness of unconscious bias, and more.

Methodology comment: ABC Arbitrage wishes to clarify that this indicator does not reflect the reality of our equal pay policy, as the regulatory calculation method does not take into account the specificities of different jobs and career paths.

This year, we were able to rely on our internal skill levels to calculate this indicator, as the headcount thresholds were met for two categories, representing more than 40% of our employees.

However, this methodology does not differentiate between the types of jobs performed. At ABC Arbitrage:

• 80% of employees are Technical Engineers and Financial Engineers (developers, quantitative traders, financial operators).
• These professions have historically been predominantly male: According to the most recent data from the Conference of Directors of French Engineering Schools (CDEFI), women represented approximately 28% of engineering students in 2023. Some highly selective programs or schools have even lower rates (for example, at École Polytechnique, only 16% of admitted students were women in 2024). These figures confirm that the underrepresentation of women in technical and quantitative fields is a structural phenomenon.

ABC Arbitrage guarantees equal pay based on objective criteria: qualifications, experience, and expertise. Pay gaps between men and women can be explained by differences in responsibilities, technical skills, seniority, or experience. They primarily result from the distribution of professions, some of which are more valued in the job market. For example, quantitative developers and traders, rare and highly sought-after positions, have a higher salary scale and are predominantly held by men within the UES (Economic and Social Unit), due to their underrepresentation in engineering schools.

Indicator related to the underrepresented gender among the ten highest salaries

Progress objective: ABC Arbitrage is committed to improving the representation of women in top-level positions by the end of 2028.
To achieve this goal, the company will implement a more transparent career path structure (internal classification, skills mapping, mobility, and performance evaluation) to ensure more equitable and equitable career advancement.
In parallel, actions will be taken to strengthen the pool of women in currently underrepresented and highest-paying roles, particularly trading and business development, in accordance with the commitments outlined in the previous section.

Methodology comment: The study of women’s representation among the ten highest earners shows that women are underrepresented among the highest-paid employees. This is explained by the fact that positions with greater technical complexity and higher salary scales (Portfolio Manager, Developers, Quantitative Traders) are predominantly held by men, as previously mentioned.

More broadly, as part of a continuous improvement approach, ABC Arbitrage has established a gender equality policy, in collaboration with an internal task force of employees. This initiative allows for the identification and improvement of actions in several strategic areas, such as recruitment, training, parental leave, and career development.