Fiscal 2020 Universal Registration Document

5. Corporate governance

5.3.3.3 Sodexo Group tax policy

The Sodexo Group has established a tax policy that has been published on its website. This policy mainly states that the Sodexo Group undertakes to respect local tax laws and regulations that apply and pay its fair share of taxes in all countries where it operates, in line with the substance of the economic activity of the business locally. Sodexo is not using intended tax structures for tax avoidance nor investing in tax structures located in so-called“tax havens” in order to avoid taxes. The tax policy complies with principles of Business Integrity and the Code of ethics of the Sodexo Group. Therefore, the Group considers that it complies with the requirements of the new article L.225-102-1 of the French Commercial Code combatting tax evasion.

Sodexo will always:

  • perform risk management assessments before adopting a tax position;
  • ensure that each controlled entity has a sound commercial, business or financial justification and has the sufficient level of substance;
  • frame transfer pricing policy for intra-Group exchanges of goods and services on an arm’s length basis, pricing in line with international standards (e.g. OECD Guidelines); this principle is applied consistently across the Group and adequately documented;
  • monitor tax compliance in jurisdictions where Sodexo operates.

All significant tax positions are regularly reported to the Group Audit Committee.

5.3.4 Vigilance Plan

Sodexo has been actively managing its risks for a long time. The legal requirements regarding the duty of vigilance therefore reflect the values and actions long championed by the Group and its founder, Mr. Pierre Bellon.

In accordance with France’s Duty of Vigilance Act, the Vigilance Plan presents the measures put in place within the Group to identify risks and prevent serious impacts in terms of (i) human rights and fundamental freedoms, (ii) individual health and safety, and (iii) environmental damage that may result from the Group’s activities and those of its subcontractors and suppliers.

As Sodexo operates in 64 countries in a variety of complex economic and socio-cultural contexts, it adapts its approach to the above issues in accordance with its different businesses and host countries. The Vigilance Plan covers Sodexo and its subsidiaries’ activities and is perfectly in line with its corporate responsibility roadmap.

In addition, the Group has put in place a dedicated governance system relating to ethics and compliance issues (including those that fall within the scope of the French Duty of Vigilance Act), as described in section 5.3.3 of this Universal Registration Document.

Issues that fall within the scope of the Duty of Vigilance cover all businesses and involve numerous teams, including Corporate Responsibility, Supply Management, Legal Affairs, Internal Control, Internal Audit, Human Resources, Ethics and Operations. The Group’s work on these issues also involves its customers, suppliers and subcontractors.

In Fiscal 2020, there was special focus on the impact of the Covid-19 pandemic on those three areas, with a special relief program set up for the Group’s employees and suppliers.

The diagram below details the measures implemented by the Group in accordance with the five obligations concerning the three categories of issues. These measures are described in more detail in chapter 2 of this Universal Registration Document.