Fiscal 2022 Universal Registration Document

7 SHAREHOLDERSAND SHARE CAPITAL

7.2 Financial communications policy

To respond more effectively to the expectations of its shareholders, Sodexo continuously works to improve its investor relations program by developing new information channels and the quality of its interactions during the different meetings with the financial community.

7.2.1 Listening to our shareholders and the financial community

In order to comply with all applicable regulations in connection with its listing on Euronext Paris (the French stock exchange), Sodexo and all the teams involved in preparing financial communications have committed to a set of transparency principles designed to ensure equal treatment of all shareholders.

Sodexo’s investor relations policy is based on four core principles:

equal treatment when disclosing quarterly financial information: all financial press releases are issued simultaneously in real time to all our stakeholders, both in French and English. These press releases are published on the Group’s website (www.sodexo.com) and relayed through the press, e-mail and via an authorized provider;
regular reporting: the financial community is informed of the financial publication schedule a year in advance, and updates are always available on the Group’s website;
ease of access to financial meetings: Annual Shareholder Meetings and revenue and results presentations are broadcasted via a live webcast and subsequently available on the Sodexo website. In addition, all financial communication is available and archived on the website;
transparency: all information on the Group, including the Company’s Bylaws, Universal Registration Document, Interim Report, press releases, presentations and share price trends, is also available on the website: www.sodexo.com.

7.2.1.1 Group spokesperson

Only the Chairwoman and Chief Executive Officer as well as the members of the Group executive Committee are authorized to provide financial communications. The Chairwoman of the Board of Directors and Chief Executive Officer appoints the Investor Relations team to act as spokespeople for the Group, within specific delegated powers.

7.2.1.2 Preparation and publication of financial communications

All financial communication is reviewed prior to publication by a Group Disclosure Committee comprising of representatives from Group Finance, Communications, Corporate Responsibility, Legal, Board Secretary and Human Resources.

Barring exceptional circumstances, all information with the potential to influence the share price is published before Euronext Paris opens for trading.

After approval of this information by the Chairwoman of the Board of Directors and Chief Executive Officer, the Chief Financial Officer or the Board of Directors (depending on its nature), it is communicated to the markets via a press release issued simultaneously to the entire financial community and to the stock market authorities.

Sodexo does not communicate financial information during the following periods:

30 calendar days preceding the date of publication of the annual and half-year consolidated financial statements;
15 calendar days preceding the date of publication of its first and third quarter consolidated financial information.

7.2.1.3 Code of conduct for senior managers

To ensure Sodexo’s commitment to transparency and regulatory compliance, the Board of Directors adopted a Code of Conduct with integrity principles for senior managers in 2003.

The Code of Conduct sets out a core set of behaviors:

to avoid actual or apparent conflicts of interest;
to comply with all laws, rules and regulations;
to protect the Group’s confidential information;
to conduct all business fairly;
to hold managers accountable for their behavior and create an environment of trust where concerns can be reported without fear of retaliation or retribution.

The Group’s ethical principle of transparency means efficient communication with the Group’s shareholders, so that they are provided with full and accurate information on the Group’s financial condition and profits. The Group is committed to timely communication and to complete, accurate, reliable and clear reporting.