Fiscal 2022 Universal Registration Document

2 CORPORATE RESPONSIBILITY AT SODEXO

Responsibility of the Statutory Auditor, appointed as independent third party

On the basis of our work, our responsibility is to provide a report expressing a limited assurance conclusion on:

  • The compliance of the Statement with the requirements of Article R. 225-105 of the French Commercial Code;
  • The fairness of the historical financial information (actual or extrapolated) provided in accordance with Article R.225-105-I (3) and II of the French Commercial Code concerning action plans and policy outcomes, including the key performance indicators on the main risks.

As it is our responsibility to provide an independent conclusion on the Information as prepared by Management, we are not authorised to help prepare said Information, as that could compromise our independence.

At the request of the entity and outside of the scope of certification, we may express reasonable assurance that the information selected by the entity, presented in the appendices, and identified by the symbol √ has been prepared, in all material respects, in accordance with the Guidelines.

However, it is not our responsibility to comment on:

  • The entity's compliance with other applicable legal and regulatory requirements (in particular, the disclosures provided for in Article8 of Regulation (EU) 2020/852 (the Taxonomy Regulation), the French duty of care law and anti-corruption and tax avoidance legislation);
  • The fairness of the disclosures provided for in Article 8 of Regulation (EU) 2020/852 (the Taxonomy Regulation);
  • the compliance of products and services with the applicable regulations.

Regulatory provisions and applicable professional guidance

We performed our work described below in accordance with the provisions of Articles A. 225 1 and following of the French Commercial Code, the professional guidance issued by the French Institute of Statutory Auditors (Compagnie nationale des commissaires aux comptes) and our own procedures relating to this engagement and International Standard on Assurance Engagements ISAE 3000 (Revised)(2).

Our independence and quality control

Our independence is defined by the provisions of Article L. 822-11-3 of the French Commercial Code and the French Code of Ethics (Code de déontologie) for statutory auditors. Our firm maintains a comprehensive system of quality control including documented policies and procedures regarding compliance with applicable legal, regulatory and ethical requirements and the professional guidance issued by the French Institute of Statutory Auditors relating to this engagement.

Means and resources

Our work was carried out by a team of twelve people between July and October 2022 and took a total of about fourteen weeks.

We were assisted in our work by our specialists in sustainable development and corporate social responsibility. We conducted some fifteen interviews with the people responsible for preparing the Statement.

Nature and scope of our work

We planned and performed our work to address the areas where we identified that a material misstatement of the Information was likely to arise.

We believe that the work carried out, based on our professional judgement, is sufficient to provide a basis for our limited assurance conclusion:

  • We obtained an understanding of all the consolidated entities' activities, and the description of the principal risks associated;
  • We assessed the suitability of the criteria of the Guidelines with respect to their relevance, completeness, reliability, neutrality and understandability, with due consideration of industry best practices, where appropriate;
  • We verified that the Statement includes each category of social and environmental information set out in article L. 225-102-1 III as well as information regarding compliance with human rights and anti-corruption and tax avoidance legislation;
  • We verified that the Statement provides the information required under article R. 225-105 II of the French Commercial Code, where relevant with respect to the principal risks, and includes, where applicable, an explanation for the absence of the information required under article L. 225-102-1 III, paragraph 2 of the French Commercial Code;
  • We verified that the Statement presents the business model and a description of principal risks associated with all the consolidated entities’ activities, including where relevant and proportionate, the risks associated with their business relationships, their products or services, as well as their policies, measures and the outcomes thereof, including key performance indicators associated to the principal risks;
  • we referred to documentary sources and conducted interviews to:
    • assess the process used to identify and confirm the principal risks as well as the consistency of the outcomes, including the key performance indicators used, with respect to the principal risks and the policies presented,
    • corroborate the qualitative information (measures and outcomes) that we considered to be the most important presented in Appendix. Concerning certain risks(3), our work was carried out on the consolidating entity, for the other risks, our work was carried out on the consolidating entity and on a selection of entities(4) ;

  • We verified that the Statement covers the scope of consolidation, i.e. all the consolidated entities in accordance with article L. 233-16 of the French Commercial Code, within the limitations set out in the Statement;
  • We obtained an understanding of internal control and risk management procedures the entity has put in place and assessed the data collection process to ensure the completeness and fairness of the Information;
  • For the key performance indicators and other quantitative outcomes that we considered to be the most important, as presented in Appendix, we implemented:
    • analytical procedures to verify the proper consolidation of the data collected and the consistency of any changes in those data,
    • tests of details, using sampling techniques, in order to verify the proper application of the definitions and procedures and reconcile the data with the supporting documents. This work was carried out on a selection(4) of contributing entities and covers between 19% and 100% of the consolidated data selected for these tests;
  • we assessed the overall consistency of the Statement based on our knowledge of all the consolidated entities.

(2) ISAE 3000: international standard on assurance engagements other than audits or reviews of historical financial information.

(3) Safety and quality of food and FM services, Food Waste, Respect of human and workers’ rights in the supply chain, Access to affordable and healthy food, local socioeconomic

impacts, Employee social dialogue, Fight Against Tax evasion

(4) Entities that were selected for limited assurance:

- Sodexo On-Site services: United States of America and France.

Entities that were selected for reasonable assurance:

- Sodexo On-Site Services: Brazil, Australia, United Kingdom & Ireland;

- Sodexo Benefits & Rewards Services: United Kingdom & Ireland.