Universal Registration Document - Fiscal 2023

2. Corporate responsibility at Sodexo

Alignment analysis

The Group has performed an assessment of alignment of its main eligible activities, in accordance the criteria stipulated in the Taxonomy:

Substantial contribution criteria and specific DNSH

Analysis of substantial contribution criteria and specific DNSH were performed for our energy management services and some of our transportation services, through workshops and data collection matrix. A critical review of the data collected was performed at Group level.

Several alignment screening workshops were conducted with Subject Matter Experts from several countries. The workshops objectives were first – to provide guidance on screening steps and equip SMEs with profound understanding of the regulation, and second – to lay out action plans for future alignment of identified eligible activities.

Two main activities were the subject of more in-depth analysis: Energy Management services and inland passenger water transport.

Energy Management Services

As part of our journey towards a net-zero objective, our energy management services are undergoing a profound transformation, becoming more sustainable and environmentally friendly. Our team of experts is diligently working on developing client site energy transition plans that shall not only meet net-zero ambition but also fulfill the EU taxonomy’s alignment criteria, solidifying our commitment to reduce energy use at all our operated sites.

Inland passenger water transport

In Fiscal 2023, Yacht de Paris invested in the 100% electrification of their boat called “Cachemire”. Sodexo Live! considers converting its remaining diesel-powered boats into hybrid or electric vessels in the coming years. The objective of this initiative is to achieve a substantial reduction in greenhouse gas emissions of the activity.

Generic DNSH

For the eligible activities of the Group to be taxonomy aligned, it is required to perform a Climate risk assessment relevant for those activities. The Group’s strategic plan identifies Climate adaptation as a major topic for the coming years, and, as a result, a study on risks, vulnerability and mitigation actions regarding physical events induced by climate change was launched in Fiscal 2023.

An analysis of climate risks was carried out at Group level without studying the specificities of the activities considered eligible within the meaning of the Taxonomy. As a result, for Fiscal year 2023, Sodexo does not meet the conditions for alignment with the green taxonomy with regard to the DNSH “climate change adaptation” (Appendix A).

Minimum safeguards

Review of minimum safeguards was performed at Group level through workshops held with the corresponding departments. Based on this analysis, the Group concluded that it complies with the four themes covered by the minimum safeguards:

Human rights

Sodexo’s commitments to Human Rights and Fundamental Rights at Work are laid out in the Human Rights Policy and the Fundamental Rights at Work charter. Sodexo is committed to respecting human rights wherever it does business. This commitment, policies and procedures are based on international texts such as:

  1. the United Nations Guiding Principles on Business and Human Rights;
  2. the Universal Declaration of Human Rights;
  3. the International Labor Organization’s (ILO) Declaration;
  4. OECD Guidelines for Multinational Enterprises.
Anti-corruption

Sodexo has documented its approach in the Sodexo’s Business Integrity Guide.

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.

Taxation

Sodexo Group undertakes to respect local tax laws and regulations that apply and pay its fair share of taxes in all countries where it operates, in line with the substance of the economic activity of the business locally (refer to 7.3.3.3 Sodexo Group tax policy).

Fair Competition

Sodexo complies with anti-trust laws, which prohibit competitors from agreeing to fix prices, rig bids or to allocate markets, geographies or clients. Sodexo Group formalized its fair and open competition approach in the Business Integrity Guide. Initiatives are put in place to raise awareness among employees and suppliers of the importance of respecting anti-trust laws.

Synthesis and outlook for Fiscal 2024

Sodexo strictly applied the regulation and none of its eligible activity or investments was qualified as “aligned” after review of technical screening criteria and analysis required for alignment, which are not, as of today, completely available.

It should be noted that Fiscal 2023 is the first year for which alignment analysis is performed. Risk assessment in relation to climate adaptation and other Taxonomy environmental objectives were not available at the level of granularity required.

Corporate responsibility has always been at the heart of our mission and everything we do. Despite limited Taxonomy-eligible activities today, we are convinced that our services bring positive impact to our employees, consumers, clients, suppliers, and shareholders.

In Fiscal 2024, the Group will review and adapt its methodology and eligibility and alignment analysis as the introduction of the Taxonomy progresses and in light of changes to the regulations, listed activities and technical review criteria.