Fiscal 2022 Universal Registration Document

6 CORPORATE GOVERNANCE

SPEAK UP ETHICS LINE

6. Whistleblowing system: Sodexo's "Speak Up" Ethics Line is 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, conflicts of interest, environmental damages, document forgery or insider trading. According to the last engagement survey (Voice) 79% of employees feel comfortable to report unethical conduct if necessary. In alignment with local laws and regulations, this system is hosted by a third-party company. All of the relevant managers have been trained on case management and responsible investigation procedures, notably through two online training sessions. More than 92% of case managers completed the e-learning modules.

  • 2,346 received cases via Speak Up Ethics Line
  • 79% of employees feel comfortable to report unethical conduct
  • 0.6 case by 100 employees
  • 57% confirmed cases reported via Speak Up resulted in a corrective action and/or sanction
BREAKDOWN OF SPEAK UP CASES BY SOURCE
This diagram shows the distribution of the speak cases by source

This diagram shows the distribution of the speak cases by source

  • Employees: 78%
  • Former employees: 11%
  • Clients/consumers: 6%
  • Suppliers: 1%
  • Other: 4%
BREAKDOWN OF SPEAK UP CASES BY CATEGORY
This diagram shows the breakdown of speak up cases by category

This diagram shows the breakdown of speak up cases by category

  • Respect at work, diversity and equal opportunities concerns: 70%
  • Employee human resources concerns: 13%
  • Business integrity privacy and legal concerns: 4%
  • Workplace health, safety and physical protection: 3%
  • Misuse or misappropriation of company resources: 3%
  • Other: 7%
BREAKDOWN OF SPEAK-UP CASES BY RESOLUTION
This diagram shows the breakdown of speak-up cases by resolution

This diagram shows the breakdown of speak-up cases by resolution

  • Sustained or partially sustained: 43%
  • Unsubstained: 37%
  • Not determined: 15%
  • Other: 5%

7. Controls: The internal control and risk management procedures related to the preparation and processing of financial and accounting information form an integral part of the Group’s anti-corruption measures. Specific controls related to Ethics, Anti-Corruption and Speak-Up are part of the annual Company Level Controls assessment, which is carried out by the majority of Sodexo’s entities (refer to section 6.4.3.4). If an entity fails these controls, then a compulsory action plan is put in place to remedy the control deficiency. These plans are monitored by the local and regional internal control managers. Internal and external audits are performed on a regular basis, notably covering the following topics: anti-corruption, anti-money laundering, environmental protection, respect of human rights and fundamental labor rights, and occupational health and safety. In Fiscal 2022, the Group Internal Audit continued its audit of entities using a risk-based approach, resulting in recommendations related to improvements in Sodexo’s Ethics & Compliance program.