Fiscal 2021 Universal Registration Document

6. Corporate governance

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;
  • establish and document a transfer pricing policy for intra-Group exchanges of goods and services on an arm’s length basis, in line with international standards (e.g. OECD Guidelines);
  • monitor tax compliance in jurisdictions where Sodexo operates.

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

6.3.4 Vigilance Plan

Sodexo has been actively managing its risks for a long time. The new 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 French law, 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 56 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, as described in section 6.3.3 above.

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.

The Group’s vigilance approach has been built around human rights, health and safety and environmental issues. No one can be exemplary if they are not exemplary within their own organization. This is why Sodexo is committed to ensuring common standards for all. This commitment is set out in our Better Tomorrow 2025 plan, in line with the recommendations of the United Nations Sustainable Development Goals (SDGs) and our declaration on fundamental labor rights.

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.