Universal Registration Document - Fiscal 2024

8. Shareholders and share capital

8.2 Financial communications policy

To better meet shareholders’ expectations, Sodexo continually enhances its investor relations program by developing new information channels and improving the quality of its interactions during meetings with the financial community.

8.2.1 Listening to shareholders and the financial community

In order to comply with all applicable regulations in connection with its listing on Euronext Paris (the French stock exchange), Sodexo and the teams handling financial communications follow transparency guidelines designed to ensure equal treatment of all shareholders.

Sodexo’s investor relations policy is based on four core principles:

equal treatment when disclosing quarterly financial information: all financial press releases are issued simultaneously in real time to all our stakeholders, both in French and English. These press releases are published on the Group’s website (www.sodexo.com) and distributed through the press, by e-mail and via an authorized provider;
regular reporting calendar: the financial community is informed of the financial publication schedule a year in advance, and updates are always available on the Group’s website;
easy access to financial meetings: Annual Shareholder Meetings and revenue and results presentations are broadcasted via a live webcast and subsequently available on the Sodexo website. In addition, all financial communication is available and archived on the Group's website during 5 years.
transparency: all information on the Group, including the Company’s Bylaws, Universal Registration Document, Interim Report, press releases, presentations and share price trends, is available on the website: www.sodexo.com.

8.2.1.1 Group spokesperson

Only the Chairwoman and Chief Executive Officer along with the Sodexo Leadership Team are authorized to provide financial communications. The Chairwoman and Chief Executive Officer also appoints the Investor Relations team to act as Group’s spokespeople, within specific delegated authority.

8.2.1.2 Preparation and publication of financial communications

All financial communication is reviewed prior to publication by a Group Disclosure Committee comprising of representatives from Group Finance, Strategy, Zones, Communications, Corporate Responsibility, Legal, Board Secretary and Human Resources.

Once approved by the Chairwoman and Chief Executive Officer, the Chief Financial Officer or the Board of Directors (depending on the nature of the information), it is shared with the markets through a press release issued simultaneously to the entire financial community and stock market authorities.

Barring exceptional circumstances, all information with the potential to influence the share price is published at 7am, Paris time before Euronext Paris opens for trading.

Sodexo does not communicate financial information during the following periods:

30 calendar days preceding the date of publication of the annual and half-year consolidated financial statements;
15 calendar days preceding the date of publication of its first and third quarter consolidated financial information.

8.2.1.3 Code of conduct - Integrity principles for senior managers

To uphold Sodexo’s commitment to transparency and regulatory compliance, the Board of Directors adopted a Code of conduct with integrity principles for senior managers since 2003.

The Code of conduct sets out a core set of behaviors:

to avoid actual or potential conflicts of interest;
to comply with all laws, rules and regulations;
to protect the Group’s confidential information;
to conduct all business fairly;
to hold managers accountable for their behavior and create an environment of trust where concerns can be reported without fear of retaliation or retribution.

The Group’s ethical principle of transparency ensures efficient communication with the Group’s shareholders, providing them with full and accurate information on the Group’s financial status and profits. The Group is committed to timely, complete, accurate, reliable and clear reporting.