Universal Registration Document Fiscal 2025

These principles inform Sodexo’s human rights due diligence, which aims to identify, prevent, and mitigate any adverse impacts linked to its business activities or relationships.

Sodexo’s Human Rights Statement goes beyond the workplace. It also covers business relationships, community engagement, grievance mechanisms, due diligence, and transparency. The Company actively promotes these standards across its operations and expects its partners to uphold the same values.

POLICIES AND RULES

Across its operations, Sodexo ensures:

• A safe, healthy, and secure workplace, including dignified living accommodations where provided.
• A diverse and inclusive environment, where hiring and promotion are based on merit and all forms of discrimination are actively opposed.
• A respectful workplace culture, free from harassment, abuse, intimidation, or violence.
• Zero tolerance for forced labor and human trafficking, with strict policies against recruitment fees and exploitation.
• No child labor, with clear age limits and compliance with local and international laws.
• Freedom of association and collective bargaining, supported even in countries with legal restrictions through alternative forms of worker representation.
• Lawful wages, benefits and work time, with timely payment and respect for legal limits on work time and rest.
• Transparent and accessible grievance mechanisms, including the confidential Speak Up ethics line, allowing anyone to report concerns without fear of retaliation.

Sodexo also promotes these standards in its business relationships, expecting clients and suppliers to uphold the same principles. The Company engages with stakeholders to address potential human rights risks and contributes to the development of the communities where it operates.

GOVERNANCE

Sodexo integrates human rights risk management into its broader internal control and compliance framework, ensuring that respect for human dignity is embedded across all business activities. This structured approach enables the systematic identification, assessment, and mitigation of human rights risks throughout the Company’s operations.

A cornerstone of this framework is the human rights risk matrix, which helps evaluate exposure to potential human rights violations. Embedded within Sodexo’s internal control processes and aligned with the Group’s People Fundamentals minimum standards applicable to all employees globally, this matrix supports proactive risk management and continuous improvement through regular assessments and audits.

The effective deployment and monitoring of Sodexo’s human rights framework at regional and country levels is ensured through a collaborative approach involving three key functions:

• The Ethics department promotes awareness of human rights principles, ensures alignment with Sodexo’s Code of Conduct, and supports the implementation of grievance mechanisms such as the Speak Up ethics line. It also leads training and communication initiatives related to human rights.
• The Human Resources department serves as the primary point of contact for human rights matters in each region and country. It ensures consistent application of the People Fundamentals, supports local human rights risk assessments, and facilitates employee engagement, training, and remediation processes.
• The Risk & Internal Control department incorporates human rights into broader risk management and internal control systems. It conducts assessments and audits to identify potential human rights risks and ensures that appropriate controls and follow-up actions are in place.

Within this structure, Human Resources teams play a central role in the regional implementation. Their responsibilities include:

• coordinating the implementation of people fundamentals and human rights standards;
• supporting local risk assessments and due diligence activities;
• facilitating training and awareness initiatives;
• acting as a liaison between operational teams and central governance bodies;
• ensuring that grievance mechanisms are accessible and responsive.

By positioning Human Resources as the key regional contact for human rights, Sodexo reinforces its commitment to embedding these principles into everyday business practices and ensuring that employees across all geographies are protected, respected, and empowered.

ACTIONS

Sodexo’s human rights risk management is integrated into its broader risk and internal control framework. This includes a structured approach to identifying, assessing, and mitigating risks related to human rights across its operations, supply chain, and stakeholder relationships.

The human rights risk matrix is a key tool used to evaluate exposure to potential human rights violations. It is embedded in Sodexo’s internal control processes and linked to the Group’s people fundamentals, which define minimum standards for all employees globally. These standards are monitored through regular assessments and audits to ensure risks are addressed proactively.

As part of this framework, Sodexo has implemented an end-to-end human rights due diligence process that applies to business activities, partnerships, and operational decisions. This process includes:

• analysis of human rights risks based on geography, type of activity, and stakeholder exposure;
• review of working conditions, including safety, wages, hours, and freedom of association;
• assessment of supplier practices to ensure alignment with Sodexo’s Supplier Code of Conduct;
• monitoring of grievance mechanisms, such as the Speak Up ethics line, to ensure accessibility and protection against retaliation;
• deployment of corrective action plans when risks or violations are identified, managed by local and regional internal control officers;
• training and awareness programs for employees and managers to embed human rights principles into daily operations.

In line with its commitment to international standards, Sodexo and the International Union of Food Workers (IUF) signed a global framework agreement in 2011 to affirm their shared dedication to respecting fundamental rights at work, particularly the freedom of association and the right to collective bargaining. This agreement also established a framework for regular dialogue between Sodexo management and employee representatives from both parties, reinforcing transparency and collaboration in addressing human rights concerns.