Fiscal 2021 Universal Registration Document

6.3.3 Ethics and Compliance

Conducting business with integrity is critical to Sodexo’s success and constitutes a fundamental pillar of the Group’s responsible business conduct commitments.

In line with this, Sodexo has chosen to appoint a Group Chief Ethics Officer, who reports directly to the Chief Executive Officer and is responsible for promoting ethical principles.

6.3.3.1 Ethics and Compliance governance

Since 2011, the Sodexo Group Ethics and Compliance Committee ensures that business is conducted responsibly, by:

• deploying an ethics and compliance culture, and related programs and policies across the Group;
• addressing a range of issues relating to anti-corruption, the duty of vigilance, and preventing conflicts of interests;
• supporting all of the Group’s Ethics and Compliance Committees worldwide;
• examining all specific issues brought to its attention.

This Committee is co-chaired by the Group General Counsel and the Group Chief Ethics Officer and comprises representatives from the various support functions: Ethics, Legal, Internal Control, Internal Audit, Human Resources, Supply Management, Corporate Responsibility, and Communications, as well as heads of certain activities (some of whom are also members of the Group Executive Committee). Two other Group Executive Committee members take part in the work of the Ethics and Compliance Committee (a region Chair and a worldwide segment CEO). These two members change every year so that all of the Group’s functions can be represented. The Ethics and Compliance Committee submits quarterly reports on its work to the Group Executive Committee. During Fiscal 2021, this Committee met seven times, either in plenary sessions or in expert meetings (to address technical issues and prepare related presentations for the members of the Group Executive Committee).

A local network dedicated to ethics and compliance issues has also been deployed throughout the Group, in particular to (i) draw up the local risk mapping, (ii) adapt the Group’s overall ethics and compliance program to the specific requirements of the country and activity concerned, (iii) report to the Group all information relating to local deployment of the program so it can be adapted where necessary, (iv) assist operations teams on a daily basis, and (v) help local executives promote a culture of integrity. This compliance community has been given dedicated systems and processes so it can access the resources needed to deploy the program globally and consistently. In this respect, each region and/or country has a local Ethics and Compliance Committee.