Universal Registration Document - Fiscal 2023

7. Corporate governance

  1. policies and procedures: Sodexo put in place its first Group wide ethics charter in 2007 and subsequently drew up its Code of Conduct called Business Integrity Guide. This document – which sets out the Group’s ethical principles – is reviewed each year. The Code of Conduct provides practical examples showing employees how to do the right thing when facing a dilemma. It is available in 30 languages and can be consulted on Sodexo.com. It is supported by policies and procedures, which give employees practical tools for guiding them in their daily work and projects, notably in relation to gifts, invitations, donations, corporate sponsorship, public affairs (a “Public Affairs Guide” has also been published for stakeholders on the Group’s website), international sanctions and high-risk third parties;
  2. training and awareness-raising: Specific training courses on Responsible Business Conduct are developed and delivered within the Group to the staff categories with the highest level of exposure. E-learning modules on Responsible Business Conduct (combating sexual harassment, data protection, public affairs, human rights in the workplace, and preventing corruption and conflicts of interest) have been put in place for all of the Group’s leaders and managers. At August 31, 2023, over 424,000 sessions of these modules had been recorded. These training modules are the subject of regular in-house communication campaigns. In addition, face-to-face training is provided to managers and some other categories of employees who are particularly exposed to the different corruption risks. 100% of the Senior Leaders have been trained on corruption prevention;