Fiscal 2020 Universal Registration Document

6.2 FINANCIAL COMMUNICATIONS POLICY

___ To respond more effectively to the expectations of its shareholders, Sodexo continuously works to improve its investor relations program by developing new information channels and in the quality of its interactions during the different meetings with the financial community.

6.2.1 Listening to our shareholders and the financial community

In order to comply with all applicable regulations in connection with its listing on Euronext Paris (the French stock exchange), Sodexo and all those involved in preparing financial communications have committed to a set of transparency principles designed to ensure equal treatment of all shareholders.

Sodexo’s investor relations policy is based on four core principles:

• equal treatment when disclosing quarterly financial information: all financial press releases are issued simultaneously in real time to all our stakeholders, both in French and English. These press releases are published on the Group’s website (  www.sodexo.com ) and relayed through the press, e-mail and via an authorized provider;
• regular reporting: the financial community is informed of the financial publication schedule a year in advance, and updates are always available on the Group’s website. In a process of acceleration of the publication of the Group’s accounts, the announcement of the Fiscal 2020 results and the Shareholders Meeting to approve those accounts are advanced by about ten days;
• ease of access to financial meetings: Annual Shareholder Meetings and revenue and results presentations are broadcast via a live webcast and subsequently available on the Sodexo website. In addition, all financial communication is available and archived on the website;
• transparency: all information on the Group, including the Company’s Bylaws, Universal Registration Document (formerly called the Registration document), Interim Report, press releases, presentations and share price trends, is also available on the website:  www.sodexo.com .

6.2.1.1 Group spokesperson

Only the Chairwoman, the Chief Executive Officer and members of the Executive Committee are authorized to provide financial communications. The Chief Executive Officer appoints the Director of Financial Communications to act as spokesperson for the Group, within specific delegated powers.

6.2.1.2 Preparation and publication of financial communications

All financial communication is reviewed prior to publication by a Group Disclosure Committee comprising representatives from Group Finance, Communications, Corporate Responsibility, Legal, Board secretary and Human Resources.

Barring exceptional circumstances, all information with the potential to influence the share price is published before Euronext Paris opens for trading.

After approval of this information by the Chief Executive Officer, the Chief Financial Officer or the Board of Directors (depending on its nature), it is communicated to the markets via a press release issued simultaneously to the entire financial community and to the stock market authorities.

6.2.1.3 Code of conduct for senior managers

To ensure Sodexo’s commitment to transparency and regulatory compliance, the Board of Directors adopted a Code of conduct with integrity principles for senior managers in 2003. Since that date, the Group’s Executive Committee members and key finance executives must systematically and formally sign up to this Code and abide by its principles.

This Code of conduct sets out a core set of behaviors:

• to avoid actual or apparent conflicts of interest;
• to comply with all laws, rules and regulations;
• to protect the Group’s confidential information;
• to conduct all business fairly;
• to hold managers accountable for their behavior and create an environment of trust where concerns can be reported without fear of retaliation or retribution.