Complementing the Code of Conduct, Sodexo has established a series of dedicated policies and procedures, including:
- a Supplier Code of Conduct, available on Sodexo website in multiple languages, which sets out mandatory principles for suppliers and business partners, including a strict prohibition of any practices contrary to the Group’s zero-tolerance stance on bribery and corruption;
- a third-party due diligence procedure, which defines the guidelines for assessing, contracting with, and monitoring third parties identified as presenting higher corruption risks;
- mergers & acquisitions guidelines, outlining the pre-acquisition due diligence steps required to identify and mitigate risks, particularly corruption risks, in M&A transactions;
- the Speak Up Ethics line policy, which sets out the framework for reporting concerns in confidence and without fear of retaliation;
- a Gifts and Hospitality Policy, which defines the rules governing the offering and acceptance of gifts and invitations;
- a conflict of interest disclosure procedure, aimed at identifying, preventing, and resolving actual or potential conflicts of interest within the Group, supported by the ethics zone portal.
Mapping of corruption risks
Specific corruption risks are assessed every two years in the Group’s main entities since 2021 at the country level and aggregated into the Group-wide corruption risk map. Assessments from the main entities have been consolidated to build a global matrix of Sodexo corruption scenarios.
Anti-corruption training and awareness-raising
Sodexo’s training program, aimed in particular at preventing and detecting corruption, combines:
- the module “Fighting Corruption” integrated into online training modules (e-learning) related to responsible business conduct, assigned to managers and leaders, with re-certification campaigns;
- in-person or hybrid training or awareness sessions, at global or local level, on integrity, ethics, and corruption or the anti-corruption system, to raise awareness among Sodexo employees particularly exposed to corruption risks and to encourage active adoption of anti-corruption rules and best practices.
Whistleblowing System: Sodexo Speak Up ethics line
Sodexo has implemented a whistleblowing system, the Speak Up Ethics Line, designed to allow anyone connected to the company to report safely and confidentially, in compliance with local laws, any behavior contrary to the law or internal rules, including possible allegations or incidents of corruption. To ensure neutrality, this system, accessible at any time online or by phone, is managed by an independent external provider. Reports can be made anonymously (where local legislation allows it) by Sodexo employees, as well as temporary staff, consultants, suppliers, clients, and any person affected by our activities.
When a report is received, it is handled either by the Ethics department or a designated local contact. A case manager, specifically trained for this purpose, is then assigned to conduct an independent and confidential investigation. Case managers operate outside the direct management chain of the individuals involved, ensuring impartiality and avoiding any conflicts of interest.
To reinforce independence and integrity, Sodexo has established a clear escalation process. If a case involves senior management, sensitive topics, or potential conflicts of interest, it is escalated to the Group ethics or to a designated senior leader who is not part of the hierarchy concerned. This mechanism ensures that investigations are conducted with the highest level of objectivity, free from influence or pressure.
The process includes safeguards to prevent interference and to guarantee that the handling of cases remains strictly confidential and impartial. Once the investigation is completed, the results are reviewed by the competent corporate bodies. A decision is then made, and the case is formally closed.
This system is part of our Code of Conduct. Sodexo considers that each individual has a role to play in promoting a work environment respectful of laws, human rights, and principles of integrity. The Speak Up Ethics Line ensures that anyone can speak freely without fear of retaliation. Any attempt to sanction or intimidate a whistleblower is strictly prohibited and constitutes a disciplinary offense. The Company is committed to preserving the confidentiality of the whistleblower’s identity as well as that of the persons concerned by the report.
Finally, to ensure transparency and continuous improvement of the system, numerical results related to Speak Up Ethics Line(number of reports, types, processing times, etc.) are shared with the Board of Directors, the GECCo, and the regional ethics and compliance committees. This approach ensures rigorous monitoring at the highest governance level and strengthens confidence in the system.
Sodexo ensures full visibility of the Speak Up Ethics Line via its intranet for employees and on sodexo.com for external partners. It is also included in the Code of Conduct and the Supplier Code of Conduct. Sodexo also organizes internal communication campaigns throughout the year, through posters, newsletters, videos, and sometimes testimonials illustrating the usefulness of the system.
In addition, a regularly conducted global survey measures the ethical culture within our organization and allows us to adjust our awareness actions accordingly.
Thus, Speak Up Ethics Line is integrated into the company’s daily practices as a concrete tool for the prevention and management of sensitive situations.