Business integrity, prevention and detection of bribery and corruption [G1-1, G1-3, G1-4]
ZERO TOLERANCE FOR CORRUPTION ALIGNED WITH OUR ETHICAL PRINCIPLES
Our zero tolerance approach to corruption is grounded in our ethical principles (loyalty, respect for people, transparency and integrity).
All employees at Sodexo must respect and enforce all applicable rules and standards in line with our Code of conduct when it comes to business integrity and fighting corruption and bribery.
Sodexo has implemented a comprehensive framework to prevent and detect bribery, corruption and influence peddling, illustrated as follows:
This image presents the full framework of Sodexo’s EGC program to prevent and detect corruption, bribery, and influence peddling. The key stages of the program are: Commitment from top management.
- Commitment from top management.
- Governance and resources.
- Code of conduct and policy.
- Risk mapping.
- Training.
- Whistleblowing mechanism.
- Disciplinary framework.
- Third-party evaluation.
- Accounting controls.
- Effectiveness monitoring.
GOVERNANCE
Senior management’s commitment
Since 2003, the SLT has demonstrated a personal and resolute commitment to ethics and compliance, embedding these principles as a cornerstone of the Company’s overall strategy. This leadership translates into direct oversight of Sodexo’s ethics & compliance program, including:
- supervision of the compliance program dedicated to preventing corruption and safeguarding integrity across all operations;
- review and validation of the Group’s corruption risk mapping, ensuring that risks are systematically identified, assessed, and prioritized;
- examination of second- and third-level control results, providing assurance that compliance mechanisms remain effective and robust.
Beyond governance oversight, the SLT also drives targeted communication initiatives, cascaded throughout the Group, which reinforce and embed a culture of ethics and compliance at every level of the organization.
Anti-corruption governance structure
In connection with the Board of Directors and the Sodexo Leadership Team, the Group Ethics & Compliance Committee (“GECCo”)— together with the Group ethics department, the Group compliance department, and the Group risk & internal control department— oversees the implementation, monitoring, and control of Sodexo’s anti-corruption framework. The Group Internal Audit (GIA) function further evaluates the robustness of Sodexo’s corruption prevention and detection system.
The GECCo is chaired by the Group General Secretary. Its members include:
- the Group General Counsel,
- the GIA Director,
- the Group Ethics Director,
- the Group Compliance Director, and
- the Committee Secretary, who also serves as Head of Projects within the Group General Secretariat.
This committee plays a central role in the governance of Sodexo’s anti-corruption system. In connection with the anti-corruption framework, its mission includes:
- promoting a culture of ethics and compliance throughout the Group, grounded in Sodexo’s ethical principles and Code of Conduct;
- monitoring ethical and compliance issues, notably through the corruption risk mapping process, reports from the Group risk & internal control department, and audits conducted by GIA;
- designing and coordinating the Ethics & Compliance Program at Group level, while supporting its deployment across countries and tailoring it to regional and regulatory specificities;
- supervising program implementation in countries, including regular reviews of Speak Up Ethics Line data and statistics, as well as deployment plans for Group policies and procedures;
- reporting to the SLT and the Board of Directors on program performance and key issues.