The committee also invites and involves representatives from key functions, such as internal control, procurement, sustainability, communications, and members of the SLT, in its meetings and deliberations.
Equivalent structures to GECCo are established at both regional and local levels to ensure the deployment and follow-up of the ethics and compliance framework across all countries where the Group operates. These bodies are responsible for developing local corruption risk mapping, and ensuring the rollout and monitoring of the ethics & compliance program. Their composition includes regional or local ethics and compliance representatives, depending on the level, as well as representatives from regional management for the RECCo, and from country management for the CECCo.
The diagram shows the hierarchy and information flows among Sodexo’s ethics and compliance committees, with arrows indicating reporting lines and regular updates.
- Group Ethics & Compliance Committee
- Responsibilities: Promote the Group’s ethical culture and program.
- Information flow: Receives and consolidates ethics and compliance information at Group level.
- Sodexo Leadership Team
- Responsibilities: Top-management commitment to fostering an ethical culture across the Group.
- Regular reporting: Receives reports from ethics & compliance committees at all levels to ensure follow-up and alignment with Group values.
- Regional Ethics & Compliance Committees
- Responsibilities: Manage and monitor ethics and compliance at the regional level.
- Regular reporting: Communicate and escalate information to the Group level.
- Regional Management Committees
- Responsibilities: Embed ethical and compliance practices in regional management.
- Regular reporting: Ensure implementation of compliance policies in local operations.
- Country Ethics & Compliance Committees
- Responsibilities: Monitor ethics and compliance at country level in line with local laws and Group policies.
- Country Management Committees
- Responsibilities: Integrate ethical standards into country strategy and operations.
- Regular reporting: Report upwards to the Regional Ethics & Compliance Committees.
Sodexo’s commitment to ethical conduct culture
Sodexo reinforces its commitment to ethical behavior through targeted training programs on responsible business conduct, specifically designed for staff in roles with high exposure to ethical risks. All leaders and managers are required to complete mandatory e-learning modules covering key topics such as combating sexual harassment, data protection, public affairs, human rights, and the prevention of corruption and conflicts of interest. These trainings are supported by regular internal communication campaigns and complemented by face-to-face sessions for roles with elevated ethical exposure.
The Code of Conduct, fully revised in Fiscal 2024 to improve clarity and accessibility, serves as a foundational framework for all entities. It is available in more than 30 languages across Sodexo and is complemented by detailed policies and procedures that offer practical guidance for ethical decision-making, including rules on gifts and invitations, donations and corporate sponsorship, public affairs, international sanctions, and human rights.
To further support ethical awareness and decision-making, Sodexo provides access to the Ethics App, a digital platform available to all employees and external stakeholders. The app offers direct access to the Code of Conduct, key policies, and practical resources, and includes a confidential whistleblowing system, Speak Up Ethics Line. It is designed to provide ethical guidance easily accessible and to encourage transparency and accountability across the organization.
Each year, Sodexo reaffirms its commitment to integrity during the responsible business conduct week, a dedicated initiative to promote ethical behavior, integrity, and accountability across the organization. This week encourages employees to reflect on responsible business practices aligned with Sodexo’s values and includes an article and a video message from the Chairwoman and CEO Sophie Bellon shared on the intranet, company-wide emails to raise awareness, and engaging activities to promote ethical behavior in daily business practices.
Sodexo also measures the strength of its ethical culture through its global engagement survey, Voice. According to the latest results, 81% of employees reported feeling comfortable speaking up and reporting unethical conduct if necessary, reflecting a strong culture of integrity and trust.
Policies
The Code of Conduct, approved by the Group’s Board of Directors and introduced by the Chairwoman & CEO, is the cornerstone of Sodexo’s anti-corruption prevention and detection framework:
- it sets out Sodexo’s zero tolerance towards bribery, corruption, and any form of undue influence aimed at securing improper business advantage.
- it highlights the main risk situations and provides clear guidance on the expected behavior of all Sodexo employees.
- it establishes links with the relevant Group policies and mandatory e-learning modules.
- it specifies that failure to comply with the Code may lead to disciplinary action, in accordance with local laws.