Universal Registration Document - Fiscal 2023

7. Corporate governance

Pillars of the Global Data Protection Program Description of key actions implemented

Pillars of the Global Data Protection Program

Transparency with regard to data subjects and raising awareness among employees

Description of key actions implemented

Transparency

Data protection teams regularly update information notices, privacy policies and other documents to ensure transparency regarding data processing. In particular, in recent years they have endeavored to specify the purposes and legal bases for this processing.

Additionally, a user platform to give consent and manage cookies and other trackers on their web browsers or cell phones has been in place since Fiscal 2020.

Awareness-raising

As an extension of the global training program for Sodexo employees on GDPR principles initiated during Fiscal 2019, a new training module was rolled out in Fiscal 2023 to remind all Group employees working on our sites and beyond of the principles of personal data protection and to prepare them, raise their awareness and have them take responsibility for the Sodexo Group’s BCR.

Other awareness-raising campaigns were held in previous fiscal years, on simple good conduct rules and the visual “We believe in Privacy” identity, which are consistent with other BCR programs.

During Fiscal 2023, the Sodexo Group also established simple rules and guidelines relating to the use of generative artificial intelligence systems. Specifically, a simple best practice “Dos and Don’ts” guide was distributed internally.