Fiscal 2022 Universal Registration Document

Impact

Although the risks of Sodexo’s operations being significantly disrupted by the Covid-19 virus have clearly reduced in the last year, it is possible that further local or regional outbreaks continue to occur, with countries restricting movement of people or initiating targeted lockdowns. Any re-occurrence may result in client site closures, which would result in less revenue generation on those sites and reduced profitability for Sodexo.

Examples of Mitigating Activities

• Monitoring on a country by country basis to anticipate potential restrictions.

• Precise and pro-active management of our workforce to adapt to changing environments, benefiting from the experience of the last two years.

• Medical Advisory Council to support our employees’ health and safety

• Rigorous follow-up on the execution of our services with strong contract management.

• Continued focus on management of cash and client receivables.

• Continued focus on strict control of selling, general and administrative costs.

Impact

The wide range of services that Sodexo proposes and its worldwide presence means that it is subject to very specific laws and regulations for its operations at both the global and local level. For example, as a food operator, Sodexo has a legal requirement to provide accurate allergen information about the food and drinks it serves. The issue of cards in Benefits and Rewards Services require compliance with anti-money-laundering laws in some countries. Changing regulatory scenarios that may also have an impact on its business include anti-corruption (Sapin II Act on transparency, fight against corruption and the modernization of economic life), and duty of care and human rights regulations (e.g. France’s Duty of Vigilance law and the UK Modern Slavery Act). Any non-compliance of Sodexo with laws and regulations or a lack of knowledge and awareness of laws and regulations either at a country level or a global level could mean:

• harm to employees, clients and consumers;

• damage to Sodexo’s reputation;

• potential financial penalties;

• criminal action being brought against the Company and its directors.

Examples of Mitigating Activities

• Legal teams deployed at the central and local levels, who provide advice to operational staff.

• Legal teams specialized by area of expertise, having recourse to external experts.

• Awareness training sessions for our employees.

• Global Ethics and Compliance Committee ensures coordination and coherence of deployment of ethics and compliance programs amongst countries. Details of these programs are provided in section 6.3.3 “Ethics and Compliance” and 6.3.4 “Vigilance Plan”.

• Sodexo Speak Up offers Sodexo employees and partners a confidential way to report activities or behaviors that are contrary to the Code of conduct or simply illegal.