POLICY ON BILATERAL CONTACTS WITH SHAREHOLDERS
UNIVERSAL MUSIC GROUP N.V.

1.

Introduction

1.

The board of directors (the Board) of Universal Music Group N.V. (the Company) has adopted thispolicy on bilateral contacts with shareholders in accordance with best practice provision 4.2.2 ofthe Dutch Corporate Governance Code (the Policy). This Policy first entered into effect on
September 21, 2021 and was most recently amended by the Board, effective as of December 31,
2023, and remains in full force and effect until amended or terminated (in whole or in part).

2.

The Company is continuously striving to improve its relations with shareholders (including
potential shareholders and other investors). The Company is committed to maintaining an open andconstructive dialogue with shareholders. Conversations with shareholders, even outside (thecontext) of a formal general meeting, are deemed to be useful for both shareholders and theCompany. In addition to communicating with shareholders at the annual general meeting and, asapplicable, at extraordinary general meetings, the Company elaborates on its financial results
during (public) earnings calls, which are widely accessible. It publishes informative annual andinterim financial information and press releases, and informs shareholders via its website. The
Company is strict in its compliance with applicable rules and regulations on inside information,
fair and non-selective disclosure and equal treatment of shareholders that are in the same position.

2.

Meetings and presentations
From time to time, the Company meets with shareholders, including at road shows, or presents toshareholders, including at broker conferences, which conferences are typically announced inadvance on the Company’s website and by means of a press release. It is the Company’s policy topost such presentations to shareholders on its website. These meetings and presentations inprinciple do not take place shortly before the publication of annual and interim financialinformation.

3.

Bilateral contacts with shareholders

1.

The Company is prepared to engage in bilateral contacts with shareholders, where appropriate.
These take place either at the initiative of the Company or at the initiative of shareholders.

2.

The Company is generally represented by its Investor Relations department during theseinteractions. However, in certain circumstances the Chairman & Chief Executive Officer (theChairman & CEO) or one or more members of senior management may lead the discussion withshareholders. A request of a shareholder to meet with one or more (other) members of the Board
shall be assessed by the Chairman & CEO, with the exception of matters that relate to the integrity1

of the Chairman & CEO or a (potential) situation of a conflict of interest, in which case theassessment will be referred to the Chairman of the Board.
3.

The Company will determine at its own discretion whether to accept invitations to engage inbilateral contacts with shareholders and it reserves the right to accept invitations only for thosecontacts where this is determined in the interests of the Company and its affiliated enterprise.

4.

The Company can request shareholders to provide certain written information in order to assess
whether a conversation outside (the context) of a formal general meeting would be in the interestsof the Company and its affiliated enterprise. This information can include the objectives of theconversation, the matters to be discussed and the shareholder’s view on these matters, theshareholder’s interest (i.e., all long, short and derivative positions in the Company) and/or further
clarification of the shareholder’s objectives, views and investment intentions.

4.

Inside information

1.

The Company is committed to providing high quality, clear, accurate and timely information to allshareholders in compliance with applicable rules and regulations, in particular those concerning
inside information, fair and non-selective disclosure and equal treatment of shareholders that are in
the same position.

2.

The Company is committed to adhering to its legal obligations relating to confidentiality and thedisclosure of inside information and strives to only disclose publicly available information during
bilateral contacts. In the event that non-public inside information is inadvertently disclosed during
any bilateral contact, the Company will publicly announce such information as prescribed byapplicable rules and regulations.

5.

Contacts between the Company and Vivendi, the Bolloré Entities and the Tencent-led
Consortium
For the avoidance of doubt, this Policy does not prejudice any of the rights and obligations ofVivendi SE (Vivendi), Compagnie de Cornouaille and Compagnie de l’Odet (jointly the Bolloré
Entities), Concerto Investment B.V. and Scherzo Investment B.V. (jointly the Tencent-led
Consortium) and the Company. The relationship between Vivendi, the Bolloré Entities, and theTencent-led Consortium is governed by the relationship agreement between them dated September
8, 2021 (the Relationship Agreement), which the Company has co-signed to acknowledge certain
provisions, which agreement, amongst other things, contains certain arrangements regarding theprovision of information by the Company to Vivendi, the Bolloré Entities and the Tencent-led
Consortium. The orderly market arrangements provision of the Relationship Agreement does not
require the Company to share inside information to the extent that such sharing would give rise toan obligation for the Company under the Market Abuse Regulation to make a general public
disclosure. For more information, please see the summary of the Relationship Agreement includedin the listing prospectus which is available on the Company’s website (www.universalmusic.com).

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6.

Miscellaneous

1.

For any further information or questions with respect to this Policy, please contact the Company’s
Investor Relations department (investorrelations@umusic.com).

2.

A copy of this Policy is published on the Company’s website (www.universalmusic.com). ThisPolicy may be amended by a resolution of the Board. Any amendments will be published on theCompany’s website.
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