Whistleblower
PolicyAs extracted from Adyen’s GlobalCompliance Handbook

The Whistleblower Policy
Adyen strives to maintain a culture where Employees are encouraged to comply with laws, regulations, Adyen’s corevalues and internal Policies, but also to ask questions and raise concerns about the business and compliance. Adyen
has incorporated this commitment into the Adyen Formula and this Compliance Handbook, including in theWhistleblower Policy.
Situations might occur in which people do not uphold the standards of business conduct and might act in a wrongfulmanner. Adyen encourages its Employees (or any other stakeholder) who are in doubt about a certain activity to rst
ask themselves “Would I, or my colleague, blush if somebody else would know about this?”. If the answer to thisquestion is ‘yes’, Employees must not continue with this activity. If still uncertain, Employees are encouraged todiscuss the matter with someone they feel comfortable with, such as a colleague, their team lead or a member of theCompliance Committee. This is also in line with the Adyen Formula.
The following policy describe the course of action to be taken when a (suspected) wrongdoing is observed and isrelevant for all the entities of the Adyen Group.
In addition, when a breach of either of the abovementioned commitments are suspected or observed, the following
policy outlines the formal reporting channels available to all Adyen Employees and/or Stakeholders, to report such
incident or behavior and to receive the relevant legal protection as a consequence of such formal report.

3.1 The Whistleblower Policy
All Employees, Shareholders, suppliers, vendors and/or contractors that the Adyen Group engages with(“Stakeholders”) are required to report ’Suspected Wrongdoings’, including incidents or situations that have or canhave major or public consequences because it involves a work related (threatening) breach of laws and/or internal
rules having a legal basis, or danger for public health, danger for the safety of persons, danger for a breach of theenvironment, danger for the proper performance of a public service or undertaking as a result of undue acts oromissions, which take place under the responsibility of Adyen as an employer.

3.1.1 Internal Reporting
The channel designed to report Suspected Wrongdoings internally is the Adyen Speak Up System, maintained by
selected members of the Compliance Committee, as per THIS Hub page.
All Stakeholders can make use of the Adyen Speak Up System and le a report on a (Suspected) Wrongdoing, alsoanonymously if preferred.
In addition, suspected violations, including those that concern one or more members of the Management Board orSupervisory Board, can be reported directly to the Chairman of the Supervisory Board (if preferred, also anonymously)
through the following address: Adyen PO Box 10095, 1001EB Amsterdam, ATTN: Chairman of the Supervisory Boardor to piero@overmarsfamily.nl.
Stakeholders also have the possibility to consult a trusted, external, and independent advisor to discuss the(Suspected) Wrongdoing via the link: https://www.huisvoorklokkenluiders.nl/ik-vermoed-een-misstand-of-inbreuk.
All reported cases of Suspected Wrongdoing will be treated con dentially in relation to the Stakeholder, unlessdisclosure is required by law in the context of further investigations or subsequent judicial proceedings or in case theStakeholder provides its consent for disclosure.
Stakeholders ling a report shall receive a con rmation of receipt of their report within seven days after reporting.
They shall receive information regarding the assessment and/or follow up of their report within a reasonable time,
however ultimately within three months after having received the con rmation of receipt. The selected members of theCompliance Committee are responsible for the assessment and/or follow up of the report.

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All reports made are recorded in the Adyen Speak Up System in accordance with Adyen's Data Privacy Policy.
Personal Data concerning both the Stakeholder who reported the Suspected Wrongdoing and the natural person who
is allegedly responsible for a breach will be protected in accordance with the applicable laws and regulations.

3.1.2 External Reporting
Stakeholders are encouraged to report any Suspected Wrongdoing within the organization rst, however they have theability to report to an external organization, appointed by law and differing per country, (including the House for
Whistleblowers (Huis voor Klokkenluiders)1, the DNB or another authorized institution in the Netherlands), for instanceif one of the following circumstances occur:• Stakeholders could not be reasonably held to report the Suspected Wrongdoing internally (e.g. if the situation isvery urgent);• Stakeholders are not satis ed with the manner in which the concern is being handled internally; or• Stakeholders have reasonable grounds to fear that reporting a Suspected Wrongdoing will lead torepercussions.
In situations where company interest(s) might be at risk, for instance integrity related breaches of nancial regulations,
it is possible to report a Suspected Wrongdoing directly to the relevant authorities. More information on the procedure
to report to DNB (in the Netherlands) is available HERE.

2. Consequences of Reporting Suspected Wrongdoings
3.3.1 No Reprisal
Adyen or any of its Employees shall not dismiss, demote, suspend, threaten, harass or in any manner retaliate against
an Employee or Stakeholder on account of them having reported a Suspected Wrongdoing in good faith, having
disclosed information relating to a concern as part of an investigation, or having participated in some other way in an
investigation relating to a concern.
Reprisals shall be considered a serious violation of both of this Policy and appropriate action will be taken to prevent
further damage to the Employee or Stakeholder in question and to discipline those responsible for the reprisals. An
Employee or Stakeholder’s right to protection from retaliation does not give them immunity in respect of any
complicity in the matters that are the subject of the reported Suspected Wrongdoing or an ensuing investigation or
judicial proceedings. The selected members of the Compliance Committee will, for a period of two years following theinitial reporting of a complaint, monitor to ensure no reprisals have occurred against the reporting Employee orStakeholder.

3.3.2 Sanctions
Any Employee or Stakeholder found to have violated laws, regulations, Policies in the Compliance Handbook, or tohave committed fraud, might be subject to disciplinary action, up to and including termination of employment, andreporting of infringement to the relevant regulatory authority in any jurisdiction. Violation of laws may subject theEmployee or Stakeholder to civil, criminal, and/or administrative sanctions.
Any sanctions, or other actions taken, shall be proportionate to the violation and measures will be taken to protect theEmployee or Stakeholder from unintended negative effects that go beyond the objective of the measure taken. In theevent that the Employee or Stakeholder in question is found not to have committed any wrongdoing, then they will beprotected against any negative effects or reprisals and this will be monitored by the selected members of theCompliance Committee.

filed at the House for Whistleblowers via this LINK.

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1 The external report can beAdyen Group or Adyen

Adyen N.V. and all its Branches and Subsidiaries.

Branches

Refers to the US Branch, the UK Branch and the European Branches of Adyen N.V..

Compliance Committee

The committee appointed by the Management Board of Adyen (chaired by the CLCO) andresponsible for monitoring compliance with nancial laws and regulations in all jurisdictions inwhich Adyen conducts business.

Data Protection Of cer(DPO)

Dedicated of cer appointed by the Management Board and responsible for coordinating of cialinvestigations or inquiries into the processing of personal data by a public authority.

DNB

Dutch Central Bank (De Nederlandsche Bank).

Employee(s)All employees of Adyen. In this context, Employees are deemed to include members of theManagement Board [and of the Supervisory Board, every person employed by Adyen Group
including Second-tier senior of cers, self-employed contractors, agency staff, secondees,
temporary staff and/or voluntary workers.

Management Board

The Board of Managing Directors of Adyen N.V. (bestuur).

Personal Data

Any information relating to an identi ed or identi able individual, processed by Adyen, either in its
capacity of a controller or processor.

Shareholder

Any individual or legal entity that is registered by Adyen as the legal owner of a percentage ofshares of the share capital Adyen N.V..

Stakeholder

All current and potential customers, Shareholders, Employees, members of the Management
Board and of the Supervisory Board, third party-vendors, partners, agent, and contractors thatAdyen engages with or is involved with.

Subsidiaries

Entities of the Adyen Group, whose shares or voting rights are owned by Adyen N.V. for 50% ormore.

Supervisory Board

The Supervisory Board of Adyen N.V..

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A public company with limited liability incorporated under the laws of, and domiciled in, theNetherlands at Simon Carmiggeltstraat 6-50, 1011 DJ Amsterdam.

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Annex I: Terminology