7.3.1.2 Ethics and Compliance program
In order to make its strategy tangible as well as meeting the applicable legal requirements, Sodexo has structured its Ethics and Compliance program around the following pillars:
- a committed management team: Sodexo’s management team embodies the Group’s culture of integrity and has a zerotolerance policy for any form of unethical practice, such as bribery, corruption, harassment, or breaches of human rights. This commitment is shown, for example, by the regular briefings made by Sodexo management and during regional events such as “integrity week” and “anti-corruption day”. In addition, dedicated awareness-raising actions have been introduced for senior leaders, as well as for regional and country Directors;
- risk assessment: Risks specific to Responsible Business Conduct have been assessed for each country and aggregated within the global risk mapping. These risks cover major issues such as bribery, corruption, breaches of human rights, antitrust practices and environmental damages. Following the renewal of the corruption risk matrix in Fiscal 2023, Fiscal 2024 focused on the update of the human rights risk scenario matrix. Each Sodexo entity then carried out a risk assessment. The assessments of the main entities have been aggregated to build a global Sodexo human rights scenario matrix;
- policies and procedures: Since Sodexo first introduced its ethics charter in 2007 and later developed its Code of conduct, the document has been regularly updated to ensure it remains relevant and effective. In Fiscal 2024, the Code has been fully revised to make it more accessible and easier to understand for all employees. As a foundational document, the Code of conduct serves as a guiding framework for all of our entities. The Code is available in more than 30 languages on Sodexo.com, and provides clear and practical examples to help employees make the right decisions when facing dilemmas. It is supported by detailed policies and procedures that offer practical tools for everyday work and decision-making. These include guidance on topics such as gifts, invitations, donations, corporate sponsorship, public affairs, international sanctions, and human rights.
- 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 (example: 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, 2024, over 380,000 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. 97% of the Senior Leaders have been trained on corruption prevention.
PREVENTION TRAINING COMPLETION RATE *
Rate based on employees assigned through global learning portal as of August 31, 2024.
This graph shows the prevention training completion rate* (see note*).
Anti-corruption. Senior leaders: 96%. Managers: 90%.
Conflict of interest. Senior leaders: 99%. Managers: 96%.
Data protection. Senior leaders: 95%. Managers: 90%.
Sexual harassment. Senior leaders: 96%. Managers: 92%.
- third-party assessment: Since 2008, Sodexo has had a Supplier Code of Conduct, which is translated into 23 languages. This Supplier Code of conduct was fully revised and published in Fiscal 2024. 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. 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 a responsible investigation procedure have been communicated to all case managers, including through online training sessions. More than 98% of case managers have completed the online training. In addition to e-learning modules, more than 80 Speak Up case managers have been trained through a full day of live training led by two external experts, in order to learn about and practice techniques for conducting an investigation.
- controls: The internal control and risk management procedures related to the preparation and processing of financial and accounting information form an integral part of the Group’s anti- corruption measures. Specific controls related to Ethics, Anti- Corruption and Speak Up are part of the annual Company Level Controls assessment, which is carried out by the majority of Sodexo’s entities (see section 6.3.4). If an entity fails these controls, then a compulsory action plan is put in place to remedy the control deficiency. These plans are monitored by the local and regional internal control managers. Internal and external audits are performed on a regular basis, notably covering the following topics: anti-corruption, anti-money laundering, environmental protection, respect of human rights and fundamental labor rights, and occupational health and safety. In Fiscal 2024, Group Internal Audit continued its audit of entities using a risk-based approach, resulting in recommendations related to improvements in Sodexo’s Ethics & Compliance program.