This flowchart shows the Ethics and Compliance Governance
For the Country Ethics and Compliance Committee, the country activity information is sent to the region or activity ethics and compliance committees. Their regular reporting is done to the country executive committees. The region or activity ethics and compliance committees do its regular reporting to the region or activity executive committees. The group ethics and compliance committee does the deploying culture and program and does its regular reporting to the Sodexo leadership team.
The Sodexo leadership team tones from the top ethical culture to the region or activity executive committees end to the country executive committees.
7.3.3.2 Ethics and Compliance program
In order to make its strategy tangible as well as meeting the applicable legal requirements, Sodexo has structured its Ethics and Compliance program around the following pillars:
- a committed management team: Sodexo’s management team embodies the Group’s culture of integrity and has a zero- tolerance policy for any form of unethical practice, such as bribery, corruption, harassment, or breaches of human rights. This commitment is shown, for example, by the regular briefings made by Sodexo management and during specific regional events such as “integrity week” and “anti-corruption day”. In addition, dedicated awareness-raising actions have been introduced for senior leaders, as well as for regional and country directors. A reflection question on ethical behavior has been embedded in the manager year-end performance review. It is completed by employees and managers to support reflection on alignment with the Responsible Business Conduct culture in the overall individual performance;
- risk assessment: Risks specific to Responsible Business Conduct have been assessed for each country and aggregated within the global risk mapping. These risks cover major issues such as bribery, corruption, breaches of human rights, antitrust practices and environmental damages. Following the renewal of the human rights risk matrix during the 2022 financial year, the 2023 financial year focused on the update of the corruption risk scenario matrix. Each Sodexo entity then carried out a risk assessment. The assessments of the main entities have been aggregated to built a global Sodexo corruption risks scenario matrix.