Universal Registration Document - Fiscal 2023

This diagram shows the Ethics and compliance program

Responsible business conduct.

We are ALL responsible.

Sodexo Code of Conduct
Anti-bribery & corruption
Prevention of sexual harassment
Prevention of conflict of interest
Data protection
Work with high risk third-parties
Responsible public affairs
Fundamental rights at work

third-party assessment: Since 2008, Sodexo has had a Supplier Code of Conduct, which is translated into 23 languages. All suppliers are required to respect this Code and also to pass on its terms and conditions to all of the participants in their own supply chains. Sodexo is continuing the deployment of its online registration tool in order to centralize information about its suppliers. This tool incorporates all of Sodexo’s requirements related to capacity, certification, geographical coverage, and regulation. It is also used to collect data on social responsibility. Suppliers benefit from a simple interface, which enables them to provide all the required information easily. The advantage for Sodexo is that the tool provides a “gateway” for the collection of information adapted to the Group’s social responsibility requirements. Suppliers are invited to respond to various questions linked to the Group’s social responsibility commitments and are required to update them throughout their relationship with Sodexo. On more specific CSR issues, Sodexo is working with an external partner, an expert in CSR performance assessment, to overhaul the management of its high-risk suppliers. The first step will identify and prioritize the risk categories, based on CSR and purchasing criteria. Subsequently, the methodology will be progressively rolled out to the suppliers included in these categories. Suppliers in purchasing categories that have historically been identified as being high-risk will also be invited to participate in a detailed document audit. A specific policy “How to work with high-risk third parties” indicates the guidelines to be followed regarding procedures for evaluating, contracting and monitoring relationships with third parties presenting a high level of corruption risk. The Group also extended its due diligence procedures for mergers and acquisitions to include specific ethics and compliance issues;

whistleblowing system: Sodexo's “Speak Up” Ethics Line, available in over 30 languages, online or by phone in each country, enables (subject to local legislation) all Sodexo employees and partners (in particular suppliers, clients and consumers) to report anything that they suspect to be unethical, particularly harassment, theft, fraud, corruption, conflicts of interest, environmental damages, document forgery or insider trading. According to the last engagement survey (Voice) 84% of employees feel comfortable reporting unethical conduct if necessary. In alignment with local laws and regulations, this system is hosted by a third-party company. In addition, a case management procedure and responsible investigation procedure have been communicated to all case managers, including through online training sessions. More than 92% of case managers have completed the online training.

3,303received cases via Speak Up Ethics Line
84%of employees feel comfortable to report unethical conduct
0.8case by 100 employees
56%confirmed cases reported via Speak Up resulted in a corrective action and/or sanction