The Adyen wayof building an ethical businessAdyenThe Adyen way of building an ethical business2

A brief historyof building
an ethicalbusiness

Dear reader, 					August 19, 2021

When we founded Adyen in 2006, we set out to change the payments
landscape. Every step towards building a tech-first payments platform has
been guided by the Adyen Formula. The Formula consists of eight principles
that help us maintain our culture – one of talking straight and including
different people to sharpen our ideas, and of making good choices to build
an ethical business and drive sustainable growth for our merchants.
To us, making good choices is inherent to ethical behavior and trust.
These have been constant themes in our decision-making over thecourse of building Adyen. Following recent conversations with a broad
set of stakeholders, we see that what we define as good choices — which
for us feels so self-evident — can do with additional disclosure.

AdyenThe Adyen way of building an ethical business

To us, making
good choices
is inherent toethical behavior
and trust.
Since our IPO, we kept you informed about how we are building Adyen, andthe processes and structures that support us in doing so ethically, in our
Annual Reports. To ensure that we are painting a clear picture of our vision
on making good choices, we have drawn up this document. Inside, youwill find the full versions of, or references to, all policies and disclosures on
ESG-related matters – of which the majority have been in place since before
we became a public company. As we did not want to wait with providing thiscontext until our next Annual Report, we considered it opportune to pair
today’s publication of results with this intermittent update.
Whether you are reading this document to better understand Adyen
before partnering with us, you’re considering joining our team, or for
research purposes, we hope that it will leave you more informed on whatmaking good choices looks like to us.

Sincerely,
Pieter, Roelant, Ingo, Kamran, Mariëtte, and Alexander

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Making good
choices inbuilding the
Adyen team

The Adyen Formula guides how we recruit, retain
and grow talent around the world. When building
the team, Formula fit is one of the key criteria
we consider. In order to do this properly, senior
management continues to spend significant timeon the hiring process, and still meets every newhire before joining the team. This approach allows
us to maintain our flat organizational structure, in
conjunction with the Adyen Formula, as we trust
the team’s ability to make good choices.

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Growing andretaining talent
We don’t believe in pre-set career paths. You join, learn, and grow in theway that fits you and the business best. We look for the best learningand growth journeys on an individual level. With the growth of the teamin mind, our rule of thumb is to promote internally. A natural result of thepace at which the business evolves, is that the team grows fast – in bothsize and responsibilities.
Over the course of building the Adyen team, we launched a myriad oflearning programs that ensure we set the team up for success, while
maintaining the freedom to create their own path. These programs range
from company-wide compliance refreshers, to role-specific education
programs and career development workshops.

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Company-wide training programs

Introduction sessions
We host our introduction sessions
to best onboard new teammembers, which are centeredaround sharing the foundational
knowledge new joiners need to be
set up for success at Adyen.
Next to our complianceonboarding modules, theprogram includes workshops
on the industry, our tech stack,organizational structure, andboard-led Formula talks.

Unconscious bias
We prioritize fair decision-making
and minimize biases throughout
all parts of the business, andtherefore host a company-wide
unconscious bias training.

Annual integrity- and securityfocused refreshers
To ensure we are operating Adyen ina safe and secure way, we run data
privacy, security, insider trading,corporate risk, and compliancetrainings for the full team. These
trainings keep the team informedon the latest developments in theseareas, and are centered aroundthe security awareness and themitigation of risks.

Function-specific training
programs
Our function-specific programs
are set up to equip every teammember with the right set ofresources and knowledge tofunction best in their role. We
are currently operating a Sales
Academy, Account Management
Academy, Operations Academy,
and Tech Academy.

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Culture and management programs

Formula Days
We are especially proud of our
Formula Days initiative. On anannual basis, the Management
Board invites team members
from all areas of the company
to join them for a day to discusscompany opportunities andgrowth challenges that are closely
related to the Adyen Formula.

Team lead training
Our team lead training program
teaches new leaders the ins andouts of mentorship and decisionmaking, and provides them withguidance on other HR-related
topics. Our Management Board
plays an active part in these
programs.

Own Your Career
We create the freedom for every
team member to find the right
direction in their careers. To
guide personal development
journeys, we host Own Your
Career workshops that focus on
maximizing every team member’s
individual potential.

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You can’t have diversity and equity
without designing for inclusion
first. We include others to sharpen
thought processes, and intentionallywelcome a broad range of voices
and encourage speaking up. Whenchallenging each other’s ideas andopinions, we grow as a team.
Pieter van der Does
Co-founder and CEO

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Diversity, Equity andInclusion
To best help our well-diversified merchant base and build for long-term
success, we need a team that comprises different perspectives.
We know that inclusion has to be designed for, and we proactively do so.
We strive for diversity in all dimensions, including but not limited to race,
ethnicity, gender, sexual orientation, age, culture, disabilities, religion,interests, and upbringing.
Ever since we founded Adyen, we built a culture that focuses on including
others. To support the Management Board in identifying DEI focus
points, we founded a DEI working group in 2020. Ensuring that we create
a comprehensive view of the team and our efforts, the working group iscomprised of Adyen colleagues from around the world.
We conducted our first DEI survey in January 2021 and will use its insights
as a quantitatively validated baseline that informs our improvement efforts,
providing valuable input for reflecting on our progress, and run it on anannual basis. Moving forward, we will provide updates on how these
efforts advance in our annual reports.

Equal employment and inclusion policies
We treat each other fairly and appreciate differences in individual needs.
We disapprove of any form of discrimination or harassment, and treat
each other with respect. We offer equal opportunities to the Adyen team,by recruiting, retaining, and promoting colleagues based on the same
performance. When we hire, promote, and reward, we question who else
was considered, whether we were fair, and why we made this decision.
We provide credit where credit is due, and explain the reasoning toothers that were considered.
Our approach to creating an inclusive environment is guided by three core
principles that center around equity – Equal Chance, Equal Pay, and Normal
Course of Life. You can find the full policies in our 2020 Annual Report.

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Remuneration
and benefits
Adyen remuneration principles
We aim to recruit and retain the best talent out there. Our remuneration
principles support this by providing guidance in competitive
remuneration.
We reward for responsibilities, performance, and extraordinary impact.
Remuneration is based on the employee’s scope of responsibilities andexperience, and may consist of fixed remuneration (base salary and sharebased payments) and variable remuneration for certain employees.
Our remuneration scheme provides for a variable remuneration component
through sales commission and a bonus plan for our account managers.
Compensation adjustments are made to ensure continued fit withthe role, the individual, and the external market. At least once a year
the Management Board reviews everyone’s current pay. Recognition
can also be given through growth opportunities — key talent who
continuously have shown to contribute to Adyen’s long-term sustainablegrowth could be awarded equity or equity-linked instruments (deposit
receipts or ordinary shares). Our full remuneration policy, including
detailed information on variable remuneration principles for our
employees, can be found on our Governance webpage.

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Management Board and Supervisory Board
remuneration
Remuneration for the Management Board and Supervisory Board isconsistent with our general remuneration principles and long-term viewof the business. The remuneration package of a Management Board
member consists of fixed remuneration only. The remuneration packageof a Supervisory Board member consists of a base fee and a committee
fee. Adyen does not award variable remuneration to the members of theSupervisory Board.
We assess our internal remuneration ratios on a yearly basis to ensurethat Management Board and Supervisory Board remuneration develops
in line with overall compensation. On an annual basis, we track possible
changes to the relevant pay ratio when reviewing remuneration levels. In
our remuneration report, which is part of our Annual Report, we reporton the internal remuneration ratios. Our Internal Audit team performs
yearly reviews on Adyen’s remuneration framework. The remuneration
policy for our Management Board and Supervisory Board can beaccessed on our Governance webpage.

AdyenThe Adyen way of building an ethical businessSocialresponsibility

Driving sustainable growth for our merchants
has always been central to our strategy, and overthe past years we have expanded our definitionof sustainable growth towards a wider societal
one. In our social responsibility initiatives we
address traditional criteria, such as offsetting ouremissions and facilitating employee volunteering,
while also taking a tech-first approach — by using
our technology to contribute positively. Our social
responsibility efforts are guided by the United
Nations’ Sustainable Development Goals (SDGs),
as they reflect the key societal and environmental
causes that are most at stake today.

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Impact technology
We are building our Impact product suite to change the landscape of givingback in the same way we have changed the payments landscape — bysolving for complexity and removing barriers. Our current offering consistsof our donation feature Giving and carbon compensation tool Restore.
By offering these easy-to-integrate features, we remove friction fromthe donation process and create additional revenue streams for ourmerchants’ preferred charities and environmental sustainability projects.
By joining forces with our merchants, we can do good at scale. To learn
more about these products, please visit our Impact webpage .

Environmental
sustainability
We believe that limiting our environmental impact is part of our license tooperate in today’s society. Therefore, we annually conduct a greenhouse gas(GHG) audit, and compensate for our CO2 and CO2 equivalent1 emissions
by investing in environmental sustainability projects. These projects support
local communities on topics such as education and economic growth.
To read more about our annual GHG emissions, and the projects we invest in,please refer to our Annual Reports.
To further build out and implement our sustainability strategy, we
have established a sustainability working group. This working groupis instrumental in determining the direction of our future sustainability
activities. Similar to our DEI working group, the sustainability working group
comprises a diverse set of team members - representing all demographics
and functions of our global team.
We believe that sustainability is a topic that should be addressed at alllevels. Our Chief Financial Officer oversees the sustainability working
group, and upholds the responsibility of its decisions to the chairman of our
Supervisory Board.

1	The measure for our greenhouse gas emissions is tonnes of Carbon Dioxide Equivalents(tCO2e) — covering the six greenhouse gases defined in the Kyoto Protocol by the United
Nations Framework Convention on Climate Change. These six gases are carbon dioxide(CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFCs), perfluorocarbons(PFCs) and sulphur hexafluoride (SF6).

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Local initiatives
Our volunteering program is centered around addressing locally relevant
issues through employee-led initiatives in the communities our teams live andwork in. We are proud of the grassroots initiatives the team sets up – initiatives
that organically emerged over the last years focused on themes such as
education on technology and gender equality in tech.
To bring all initiatives to a success, we support the team by providing therequired resources (e.g. time and funding) as long as the initiative supports atleast one of the United Nations’ SDGs.

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Unconventional ideas often turnout to be the best ones. To foster aculture of creativity while growing at
speed, we pair the Adyen Formulawith supporting policies to makegood choices throughout all stagesof our growth journey.
Mariëtte Swart
Chief Legal & Compliance OfficerAdyenThe Adyen way of building an ethical business

Safely andsecurelybuilding
Adyen

We view security and privacy as a responsibility ofthe entire Adyen team, and we ensure every aspectof our business centralizes security awarenessand risk mitigation. Our solid and transparent
governance model and three-lines-of-defense
model allows us to focus on growing our businesswith the appropriate structures in place.

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Information security
Information security is of vital importance to us, as we process ourmerchants’ data and the data of their customers. As we collect, process,store and transmit cardholder data, we are required to comply with the
Payment Card Industry Data Security Standards (PCI DSS). PCI DSS isa global set of security guidelines that ensure companies who handle
cardholder data maintain a secure environment. Adyen fully complies
with the PCI DSS standards applicable to us.
Making sure that the data Adyen processes is appropriately prioritizedthrough the business, Adyen operates an Information Security program.
This program helps us to ensure the ongoing confidentiality, integrity
and availability of data, systems and processes at Adyen. Upon hiring,
every member of our team is required to participate in a security training
program, followed by a general security introduction which addresses
privacy and confidentiality policies. Our employees participate in annual
security refresher trainings, where we address topics such as our
password policy, our approach to removable media and cloud services,
information classification and handling, and security awareness andincident reporting. Furthermore, access to information and systems at
Adyen is on a need-to-know basis only. All employees sign an Information
Security Agreement to ensure compliance with such policies is maintained
and undesirable behavior with confidential information is avoided.
Our Information Security team supports employees in understanding
the responsibility that comes with having access to sensitive information.
We are all responsible for the management of the risks of leakage,
unauthorized modification or loss of information, systems, applications
and processes in use.

Privacy and dataprotection
We are building Adyen to support our merchants’ growth, and understandthat the trust we have been given by our merchants to process personal
data is key to successfully doing so. Building for the long term meansbuilding a platform that has privacy ingrained in its design.

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In order to run our business effectively, we need to collect and process
certain information, when processing payments, reaching out to prospect
merchants, onboarding customers, sending out newsletters, andmanaging employment. We do this in compliance with applicable laws,
safely and securely.
We see data privacy as a responsibility for everyone at Adyen. Therefore,
the Privacy team works in close collaboration with the Information Security
team, and is closely involved in both strategy setting and day-to-day
operations (e.g. launching new products and expanding into new markets).
Every new joiner is comprehensively trained on data privacy andconfidentiality principles, and we have annual mandatory refresher
trainings in place to remind all team members of the significance of
keeping our data and our merchants’ data safe. In addition, we host internal
awareness campaigns when it comes to data privacy and protection.
The entire Adyen team is responsible for reporting any suspected
or identified breach of security leading to the accidental or unlawfuldestruction, loss, alteration, unauthorized disclosure of, or accessto, personal data transmitted, stored or processed by Adyen to the
Information Security Team and Data Protection Officer. Find more
information on our global privacy approach in our 2020 Annual Report.

Risk approach
Culture is a key aspect of risk management. Our team establishes
our mission, strategy, and business objectives, and we believe that
our company culture guides our team in making the right decisions.
Therefore, we convey and safeguard the key elements of our culture
through the Adyen Formula and the Adyen Way of Being in Control. For
more extensive risk statements, please refer to our 2020 Annual Report.
We have adopted the three-lines-of-defense model, which reflects thesegregation between our operations teams (first line management),
the risk management and compliance functions (second line) which
set control standards and carry out monitoring, and the independentinternal audit function (third line) that provides assurance on theadequacy of the first two lines.

AdyenThe Adyen way of building an ethical businessA tech-firstpayments
platform built
on integrity

We believe that building an ethical business isdriven by ethical and integrous behavior, and wehave consciously built our organizational structure
to guarantee such behavior. We see making good
choices as a responsibility for the full Adyen team.
As stated throughout this document, the Adyen
Formula and our internal compliance handbook
promote integrous and ethical conduct. The
compliance handbook is a central part of ouronboarding process, and we continuously train andeducate the team on the topics in the handbook.

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Whistleblower reporting
At Adyen, we strive to maintain a culture where everybody is encouraged
to ask questions and raise concerns about all aspects of the business.
This also promotes internal discussions and sharing of ethical principles
and behaviors. We actively promote the team to always test theirconcerns with our ‘no blush’ principle and to discuss matters withcolleagues or their team lead.
Whenever a social or business interest might be at risk as a result of an
actual or threatened breach of any laws, wrongdoings are suspected, or the
standards of business conduct appear as having been violated, employees
are required to report their concerns internally. This report is made either
to managers or, in case of escalation, externally to the Dutch Central Bank
(DNB). No type of retaliation, harassment, intimidation, or threats against
whistleblowers is tolerated at Adyen. Our full Reporting and Whistleblower
policy can be found on our Governance webpage.

Conflict of interest
Adyen has adopted internal controls to prevent, identify, and document
all conflicts of interests (as well as situations that create the appearanceof conflicts of interest) that may take place whenever someone’s privateinterests interfere with the interests of Adyen or its external parties. This is
in line with Adyen’s commitment toward its broader stakeholders and its
external parties not to compromise the legitimate interests of the company.

Anti-corruption
and anti-fraud
We maintain a zero-tolerance policy for corruption and fraud, and expect
our team to uphold the highest level of integrity. To protect Adyen’s
business and reputation from wrongful acts and to prevent violation of any
bribery and corruption laws and treaties, we have adopted anti-corruption
and anti-fraud practices. For these purposes and in line with our internal
policies, our employees are not allowed to make or promise to make, or
directly or indirectly accept, any payment of monetary compensation
to or from any company or government official, which is for the purposeof inducing or influencing such person to assist in facilitating, obtaining,retaining or securing any unethical business advantage.

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Antitrust andcompetition law
At Adyen, we uphold integrity and promote fairness in all parts of thebusiness. We are committed to ensure that Adyen employees avoid any
engagement in anti-competitive practices and are aware of competition
law requirements applicable in every jurisdiction wherein we operate.
Conducting our activities in accordance with all applicable regulations andbest practices, Adyen is committed to pursuing its commercial activities
and goals in complete independence of industry competitors and based on
its own strategic decisions and guidance.

AML, CTF and sanctions
As a globally operating financial institution, we are responsible forpreventing the misuse of the financial system from money laundering andfinancing terrorism activities. We have adopted and implemented extensive
know-your-customer (KYC), know-your-business (KYB), and customer
due diligence (CDD) practices. These procedures also serve to identify,
verify, and assess all merchants, relations and affiliated persons, and to
avoid the processing of transactions that are not aligned with the laws andregulations in the countries wherein we operate.

Human rights
To build an ethical business, we promote ethical behavior and respecthuman rights. Our approach to respecting human rights is based on the
Universal Declaration of Human Rights, and we are committed to treating
all colleagues, partners, and any other stakeholders equally.

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Responsible
partnerships
We trust our team in making good choices when selecting suppliers,
and assess our suppliers’ procedures when it comes to integrous
operations before engaging in any agreement. We aim to establish
relationships with third parties2 that actively pursue compliance withsocial safeguards as mandated by Dutch law (Child Labor Due Diligence
Act), EU regulations (European Convention on Human Rights) and therequirements mandated in the jurisdictions where Adyen operates. Our
suppliers must comply with all applicable regulations and laws regardinganti-fraud, anti-corruption, anti-money laundering, and anti-competition.

Disclosure andbilateral dialogue
At Adyen, we acknowledge and endorse the importance of fair disclosureand transparency towards shareholders, investors, analysts, press
and other parties, as well as dialogues and regular interactions withthese stakeholders. Our Disclosure Committee oversees all relevant
communications and disclosures and assists the Management Board inensuring compliance with regulatory disclosure requirements.
We ensure that all shareholders and other market participants have equaland simultaneous access to information by publishing bi-annual shareholder
letters and (interim) financial statements, annual reports, and press releases,
as well as hosting Capital Markets Days and participating in investor
conferences. In this respect, meetings with or presentations to relevant
stakeholders will not take place shortly before publications of financial
statements. During the 30 calendar days prior, we limit our communications
and take caution to not provide any information or guidance on matters that
could potentially impact our performance or financial outlook.
To prevent the misuse or inadvertent disclosure of confidential information,
we educate our team to follow set procedures and principles with regards toconfidentiality. The full Disclosure and Bilateral Dialogue policy can be foundon our Governance webpage.

2	We define a Third Party as any business, company, or other entity not belonging to the
Adyen Group that is undertaking an outsourced function for Adyen.

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About Adyen
Adyen (AMS: ADYEN) is the payments platform of choice for manyof the world’s leading companies, providing a modern end-to-end
infrastructure connecting directly to Visa, Mastercard, and consumers'
globally preferred payment methods. Adyen delivers frictionlesspayments across online, mobile, and in-store channels. With offices
across the world, Adyen serves customers including Facebook, Uber,
Spotify, and L’Oréal.
Adyen was founded in 2006 – as the existing payments technology
consisted of a patchwork of systems built on outdated infrastructure.
With the aim of helping businesses grow, the Adyen team set out to build
a platform capable of meeting the rapidly evolving needs of today's fastgrowing global businesses.
Adyen focuses on building a modern infrastructure directly connected tocard networks and local payment methods across the world, allowing for
unified commerce and providing shopper data insights to merchants.
The Adyen platform enables merchants to accept payments in a single
system, enabling revenue growth online, on mobile devices and at pointof sale.