Universal Registration Document Fiscal 2025

2 Sustainability at Sodexo

CLIMATE TRANSITION PLAN IMPLEMENTATION [E1-1, E4-1]

To help its operational teams achieve the Group’s carbon reduction objectives in 43 countries, Sodexo provides them with a low-carbon strategy analysis and planning solution named Carbon Trajectory Tool developed by its partner, Tennaxia. This tool offers a personalized action plan based on the identification of the main sources of carbon emissions and the efforts that can be made to reduce them. Via this solution, countries can choose from a catalog of more than 30 operational actions linked to each one of the climate strategy pillars. This enables countries teams to create carbon reduction plans, quantify their impact before launching their program and then measure the progress.

To support the implementation of the climate transition plan, additional mechanisms have been put in place:
  • Leadership incentives aligned with Net Zero 2040: as detailed in section 7.3 Compensation, executive compensation is tied to progress on climate goals, including achieving 100% renewable electricity, reducing food waste and increasing the share of sustainable recipes, in line with Sodexo’s science-based targets.
  • Building internal climate expertise: Sodexo is investing in building internal climate expertise by upskilling employees across functions. Through targeted training on climate change, carbon accounting methodologies, and emission reduction levers, the company is fostering a workforce that is equipped to contribute meaningfully to its Net Zero 2040 ambition.
Allocation of financial resources for the climate transition plan [ESRS E1-1, E1-3]

Sodexo’s climate transition plan is fully integrated into the Group’s strategic and operational model. As an asset-light company, Sodexo does not operate industrial facilities or own significant physical infrastructure, which means its transition to a low-carbon business model does not rely on major capital expenditure programs. Instead, our decarbonization approach focuses on transforming the core of our value proposition: the way we source, design, and deliver food and services, which allows us to generate significant emissions reductions without heavy capital investment.

Approximately 70% of Sodexo’s total GHG emissions are linked to purchased goods and services, particularly the food we buy and serve. As a result, most of our transition levers — and therefore our resource allocation — focus on responsible sourcing and sustainable eating. This involves shifting towards more plant-based and seasonal menus, influencing consumer choices through behavioral nudges and carbon labelling, and working closely with suppliers to improve agricultural practices, reduce embedded emissions, and eliminate deforestation from our supply chains. These initiatives do not require significant capital expenditure but rather strategic procurement choices and contractual partnerships aligned with our net-zero objectives.

Operational expenditure (OpEx) linked to the transition plan is primarily dedicated to building and strengthening internal capabilities and specialized expertise. This includes expanding our sustainability, sourcing, and menu innovation teams, as well as engaging external experts and consultancy partners to support our work on low-carbon menu design, supplier engagement, and science-based sourcing strategies. Additional OpEx relates to the deployment of digital tools and data systems that support emissions measurement, traceability, and performance tracking.

Over the medium to long term, Sodexo expects the financial resources allocated to the transition plan to remain stable and proportionate to business growth. The Group does not anticipate major changes to the useful life of assets, nor significant capital investments directly related to the decarbonization strategy. Instead, the reallocation of existing resources, combined with a stronger focus on procurement, innovation, and partnerships, will remain the primary driver of emissions reduction and support the Group’s trajectory to Net Zero by 2040.

The Group’s climate transition plan is also the result of a comprehensive analysis conducted in 2022, which included a dedicated assessment of its potential financial implications. As part of this exercise, Sodexo evaluated the expected impacts of the transition plan on both CapEx and OpEx. The results confirmed that, given the Group’s asset-light model and the strong focus of the plan on business transformation rather than infrastructure investments, the financial impacts are expected to remain limited compared to the Group’s overall expenditure. Since this initial analysis, investments have already been directed towards strengthening our internal sustainability capabilities — including the expansion of dedicated teams, training programs for employees on climate-related topics, and specific training for chefs on sustainable cooking practices. In addition, Sodexo has invested in a carbon trajectory tool, now available across all countries, to support the effective monitoring and implementation of our Net Zero strategy. As a result of these early actions, no significant additional OpEx or CapEx is anticipated in the coming years, and the financial resources dedicated to the climate transition plan are expected to remain stable and proportionate to the Group’s activity.

GHG REMOVALS AND GHG MITIGATION PROJECTS FINANCED THROUGH CARBON CREDITS [E1-7]

Sodexo does not currently engage in GHG removals or finance GHG mitigation projects through carbon credits. At this stage, the Group is focused on reducing emissions across its own operations and value chain. In line with SBTi Net-Zero guidance, Sodexo recognizes that high-quality carbon removals may play a role in addressing residual emissions. We are therefore monitoring market developments and the forthcoming SBTi guidance to determine whether, and under what conditions, such instruments could be relevant for Sodexo in the future.

INTERNAL CARBON PRICING [E1-8]

Sodexo does not have a formal, internal carbon pricing mechanism in place. Over the past years, the Group has been using carbon prices for decision-making in some specific projects.

In 2022, as part of the scenario analysis, Sodexo has used the carbon price as a key variable impacting Sodexo, when estimating the impact on Sodexo Underlying Operating Profit (UOP) on short, medium and long term. This variable was calculated by considering regulation that may increase the price of carbon globally.

A carbon price aligned with the prices of regulated carbon taxes are also used occasionally, such as in some acquisition projects, or assessment of specific activities. In this case, it is used as a shadow price, to assess an approximate price of aligning those specific projects with Sodexo ambitions.

Outside of those specific instances, Sodexo does not use internal carbon prices in decision-making, as it does not apply to the way it operates services and projects.

ANTICIPATED FINANCIAL EFFECTS FROM MATERIAL PHYSICAL AND TRANSITION RISKS AND POTENTIAL CLIMATE-RELATED OPPORTUNITIES [E1-9]

Sodexo has not yet quantified or reported the anticipated financial effects of material physical and transition risks, nor the potential climate-related opportunities, in the current risk assessment. In line with CSRD requirements and evolving best practice, Sodexo will start the assessment of the anticipated financial effects to ensure that the financial implications of climate-related risks and opportunities are systematically considered.