In order to make its strategy tangible as well as meeting the applicable legal requirements, Sodexo has structured its Ethics and Compliance program around the following pillars:
1. A committed management team: Sodexo’s management team embodies the Group’s culture of integrity and has a zero tolerance policy for any form of unethical practice, such as bribery, corruption, influence peddling or breaches of human rights. This commitment is shown, for example, by the regular speeches made by the Chief Executive Officer and senior managers, particularly during the United Nations International Anti-Corruption Day on December 9, 2020. In addition, specific awareness-raising actions have been introduced for managers, as well as regional and country directors, regarding the increased risks of breaches of ethical principles in the context of the Covid-19 pandemic;
2. Risk assessment: risks specific to responsible business conduct have been assessed for each country and aggregated within the global risk mapping. These risks cover major issues such as bribery, corruption, breaches of human rights, anti-trust practices and environmental damage. During FY21, a strengthened corruption risk scenario matrix was put in place. A series of 30 workshops with both operational and functional participants was run across the world by the internal control and legal communities as a joint exercise to identify possible Sodexo scenarios. The scenarios identified during the workshops were consolidated and used to build a corruption risk scenario catalogue. This catalogue was then used to carry out a full country risk assessment. Each country identified its own specific scenarios and assessed them using Sodexo’s global risk criteria of impact, likelihood and level of control (see 6.4.2.4 Risk Assessment Methodology). Local scenarios could be included, as well as scenarios from the catalogue. Separate risk assessments were run for each Sodexo activity in the country – On-site Services, Benefits & Rewards Services and Personal and Home Services . The assessments from the main entities were then aggregated to build a global corruption risk scenario matrix;
3. Policies and procedures: Sodexo put in place its first Group-wide ethics charter in 2007 and subsequently drew up its Code of conduct. This Code – which sets out the Group’s ethical principles – is reviewed each year. The Code of conduct provides practical examples showing employees how to do the right thing when faced with a dilemma. It is available in 30 languages and can be consulted on the Sodexo website. It is rounded out by policies and procedures, which give employees practical tools for guiding them in their daily work and projects, notably in relation to gifts, invitations, donations, corporate sponsorship, public affairs (a “public affairs guide” has also been published for stakeholders on the Group’s website), international sanctions and “high-risk third parties”;
4. Training and awareness-raising: specific training courses on responsible business conduct are developed and delivered within the Group to the staff categories with the highest level of exposure. E-learning modules on Responsible Business Conduct (combating sexual harassment, data protection, public affairs, human rights in the workplace, and preventing corruption and conflicts of interest) have been put in place for all of the Group’s leaders and managers. At August 31, 2021, over 168,000 sessions of these modules had been recorded. These training modules are the subject of regular in-house communication campaigns. In addition, face-to-face training is provided to Executive Committee members and some other categories of employees who are particularly exposed to the different corruption risks. 100% of the Senior Leaders have been trained on corruption prevention;
5. Third-party assessment: since 2008, Sodexo has had a Supplier Code of conduct, which is translated into 23 languages and is regularly updated. The Group’s suppliers are required to respect this Code, which is included as an appendix to all commercial contracts, and also to pass on its terms and conditions to all of the players in their own supply chains. Sodexo is continuing the deployment of its online registration tool in order to centralize information about its suppliers. This tool incorporates all of Sodexo’s requirements relating to capacity, certification, geographical coverage, and regulation. It is also used to collect data on social responsibility. Suppliers benefit from a simple interface, which enables them to provide all the required information easily. The advantage for Sodexo is that the tool provides a “gateway” for the collection of information adapted to the Group’s social responsibility requirements. Suppliers are invited to respond to various questions linked to the Group’s social responsibility commitments and are required to update them throughout their relationship with Sodexo. On more specific CSR issues, Sodexo works with an external partner, an expert in CSR performance assessment, to overhaul its management of high-risk suppliers. The first step will identify and prioritize the risk categories, based on CSR and purchasing criteria. Then, the methodology will be progressively rolled out to the suppliers included in these categories. Suppliers in purchasing categories that have historically been identified as being high-risk will also be invited to participate in a detailed document audit. In Fiscal 2021, the Group published a policy entitled “How to work with high-risk third parties” indicating the guidelines to be followed regarding procedures for evaluating, contracting and monitoring relationships with third parties presenting a high level of corruption risk. Each country is responsible for developing an appropriate procedure to enable these guidelines to be implemented at a local level. The Group also extended its due diligence procedures for mergers and acquisitions to include specific ethics and compliance issues;
6. Whistleblowing system – Speak Up: the Sodexo Speak Up Ethics Line – available in over 30 languages, online or by phone in each country – enables (subject to local legislation) all Sodexo employees and partners (in particular suppliers, customers and consumers) to report anything that they suspect to be unethical, particularly harassment, theft , fraud, corruption,
