Universal Registration Document - Fiscal 2023

6.3.5 Internal controls relating to the preparation of accounting and financial disclosure

6.3. Risk factors

6.3.5 Internal controls relating to the preparation of accounting and financial disclosure

The internal control process is supported by a network of local internal control managers and coordinators embedded in the business, supported by a small central internal control team. Their role is to:

  • facilitate entity risk assessments by carrying out risk interviews;
  • assist in the documentation of controls with control owners;
  • support the implementation of new controls;
  • carry out entity testing of strategic controls relating to the control environment and process controls;
  • support Group Internal Audit in the follow-up of the implementation of its recommendations.
Self Assessment of Internal Control

The self assessment of internal control is a mature process within the Group.

A very large number of Group entities prepare a detailed report (Company Level Control Report) on their control environment based on the five components of the reference framework and which includes an evaluation of the subsidiary’s principal risks, a description of risk management measures and an assessment of their effectiveness.

The most significant Group entities go beyond this initial phase, and evaluate the effectiveness of additional controls determined by their own risk assessment (Process Level Controls). Some of these controls are also subject to effectiveness tests performed by independent persons (Group Internal Auditors).

An executive summary of the status of internal controls and the progress achieved is submitted to the Audit Committee at the end of the fiscal year.

6.3.5 Internal controls relating to the preparation of accounting and financial disclosure

Group Finance is responsible for ensuring the reliability of financial and accounting information. A process is in place to produce and analyze financial information at both operational sites and in the Group and local Finance teams.

Local Finance teams produce a monthly cumulative income statement starting at the beginning of the fiscal year, a balance sheet, and a statement of cash flows. On a quarterly basis, they also produce projections for the full year. Financial statements are consolidated on a monthly basis by Group Finance.

At the half-year, the external auditors conduct a limited review of the interim financial statements.

At the end of the fiscal year, the Region Chief Executive Officers and Chief Financial Officers certify the reliability of their financial statements, prepared in accordance with IFRS standards. The external auditors of the main entities express a view on these financial statements in accordance with their mandate from Sodexo’s shareholders. Group Finance monitors changes to IFRS standards and interpretations and ensures that the accounting treatments applied by all entities are compliant with Group rules.

Twice a year, Group Finance identifies the events that may have led to one or several assets being impaired, notably goodwill and intangible assets (in accordance with IFRS). Where appropriate, the carrying amount of the asset concerned is written down in the financial statements.

Region Chief Executive Officers and their Leadership Teams, review operational and financial reporting (comprising improvement metrics for client retention, sales development and comparable unit revenue growth) before presenting it to the Sodexo Leadership Team. In addition, quarterly business reviews with each of the Group’s activities and regions give the Group Chief Executive Officer and Group Chief Financial Officer insight into performance trends for the regions based on the financial reporting and operational information.

Procedures are in place to identify off-balance sheet commitments. This term covers all rights and obligations that may have an immediate or future impact on Sodexo’s financial position but are not recognized (or are only partially recognized) in the balance sheet or income statement. These include items such as assets pledged as security; guarantees relating to operating contracts (for example bid bonds or performance bonds), to borrowings, or to claims and litigation; lease obligations not recognized in the balance sheet; commitments under call or put options. Off-balance sheet commitments are presented regularly to the Board of Directors.

The Sodexo Tax Department defines the Sodexo Group Tax Policy. The policy is designed to achieve tax consistency worldwide and to ensure that appropriate taxes are paid in line with local tax rules in the various geographic regions in which Sodexo operates. The local and regional tax teams ensure that significant changes in local, European & worldwide tax laws are anticipated and correctly applied at country level, by advising and assisting operational teams.

The Sodexo Legal Department (comprised of a Group team and regional and local teams) works pro-actively with business development and operational teams to ensure legal compliance and support contract negotiations, so that risks pertain solely to contractual obligations for services and are limited in value and duration. Lastly, using the financial information reported and consolidated, the Chairwoman and Chief Executive Officer, assisted by the Group Financial Communications team, prepares the Group’s financial communication. The Chairwoman and Chief Executive Officer also relies on the operating data required to prepare the Universal Registration Document. The interim and annual results press releases are submitted to the Board of Directors for approval.

To enable the Chairwoman and Chief Executive Officer to provide reliable information on the Group’s financial situation, a Disclosure Committee comprising representatives from the Group’s corporate functions reviews all financial information prior to publication. Members represent the following functions: Financial Control, Financial Communications, Legal, Internal Control Human Resources, Sustainable Development and Communications and the Board Secretary.