Universal Registration Document - Fiscal 2024

6.1 Definition and objectives of risk management and internal control

The purpose of Sodexo’s risk management and internal control systems are to:

• protect the Group’s value, assets, business model, employees and reputation;
• identify and evaluate the risks that could prevent the Group from achieving its business and financial objectives;
• anticipate changes in these risks;
• put in place mitigating actions and risk transfer measures.

Sodexo’s risk management systems are designed to ensure that risks are:

• properly identified, evaluated and prioritized;
• efficiently mitigated;
• regularly reported and monitored.

Sodexo’s internal control procedures are designed to give reasonable assurance that:

• laws and regulations are complied with;
• Group policies and guidelines are properly applied;
• internal processes are functioning correctly;
• financial and non-financial reporting is reliable.

Internal control procedures also underpin the good and efficient management of Sodexo’s operations.

Group Policies

In order to support its objectives, and as part of its risk governance and management framework, Sodexo has established a number of Group policies. These policies cover subjects such as responsible business conduct, fundamental human rights at work, health and safety and food safety, human resources, procurement, corporate responsibility, information security, data protection and internal audit. Policies are updated on a regular basis.

Sodexo's Code of conduct

The Group’s standards for responsible business conduct are set out in the Code of conduct - Business integrity guide. Sodexo employees must never compromise adherence to these standards for financial or other business objectives or personal gain. Sodexo does not tolerate any practice that is not born of honesty, integrity and fairness, anywhere in the world where it does business.

During the course of Fiscal 2024, the Code was completely renewed, to make it more accessible and easier to understand for all employees.

Statement for fundamental human rights

Sodexo is committed to respecting human rights wherever it does business. This commitment, is supported by core policies and procedures which are based on international charters such as the Universal Declaration of Human Rights and the International Labor Organization’s Declaration of Fundamental Principles and Rights at Work. It is also based on the principles set forth in the OECD Guidelines for Multinational Enterprises and the United Nations’ Guiding Principles on Business and Human Rights.

The Sodexo Statement of Respect for Human Rights sets out standards for fundamental human rights at work. It covers the workplace, but also business relationships, communities, reporting concerns, due diligence and transparency. It is also accompanied by a guide and training that provides best practices and examples.

Health and safety policy and food safety policy

At Sodexo, we believe that all incidents are preventable. It starts with nurturing a Zero Harm health and safety culture. Our ambition is to be the safest place to work and the safest Company to do business with.

Sodexo’s Global Health and Safety and Food Safety Policies outline our fundamentals and standard principles to guide our behaviors, responsibilities and commitments that include:

• complying with legal, regulatory and internal standards as a condition of employment;
• identifying, evaluating and managing risks;
• ensuring adequate resources, training and capability;
• personal accountability for people and food safety by speaking up to challenge unsafe behavior, stop unsafe work and promptly report incidents, near misses and unsafe conditions or behaviors;
• fostering a Zero Harm mindset culture for people safety and for food safety from farm to fork;
• protecting and promoting the safety of our food and the health of our consumers;
• striving for operational excellence at every step in our health and safety and food processes;
• monitoring and improving our health and safety and food safety performance.