Universal Registration Document Fiscal 2025

Disciplinary measures

The relevance and effectiveness of Sodexo’s anti-corruption program are reinforced by the possible application of disciplinary sanctions to employees concerned, in accordance with the internal regulations and applicable local law, regardless of their hierarchical level or function.

Internal and accounting controls

Internal control and risk management procedures related to the preparation and processing of accounting and financial information are an integral part of the Group’s anti-corruption framework. Specific controls related to ethics, anti-corruption, and the Speak Up Ethic Line are integrated into the annual Company Level Controls assessment, conducted by the majority of Sodexo entities. If an entity fails these controls, an action plan must be implemented to address the identified deficiencies. These plans are managed by local and regional internal control officers.

Evaluation of the framework

In addition, Group audits are conducted regularly to assess the robustness of the anti-corruption prevention and detection system through two complementary approaches:

• specific anti-corruption audits (“ABAC Audits” – anti-bribery anti-corruption), and
• anti-corruption controls integrated into standard entity or process audits covering all operational and functional processes of the Group.

At the conclusion of these audits, the Group internal audit department issues recommendations for improvements to Sodexo’s Ethics and Compliance program.

Action plan in Fiscal 2025 and 2026

During this fiscal year, Sodexo carried out or continued the actions listed below:

• communicate and deploy the revised Code of conduct;
• revamp the anti-corruption and conflict of interest e-learning modules;
• conduct a new corruption and bribery risk mapping throughout the Group;
• deploy the gifts and hospitality policy that was revised in Fiscal 2024;
• continue communicating widely about Sodexo Speak Up Ethics Line;
• continue deploying the conflict of interest disclosure tool EthicsZone;
• revise the third party corruption risk evaluation policy.

In the coming fiscal year, Sodexo plans to :

• complete the mapping of corruption and bribery risks;
• release the anti-corruption and conflict of interest e-learning modules on the new Group learning platform;
• release the anti-corruption and conflict of interest e-learning modules on the new Group learning platform;

METRICS

Training rate for functions most exposed to the risk of corruption [G1-3]

The functions at risk, i.e., those most exposed to corruption risks within Sodexo, have been defined in accordance with the Group’s organization and the three lines of defense model. They include operational departments, commercial functions, and support functions (including Group Internal audit), as well as the SLT.

As of August 31, 2025, 80% of these at-risk functions have successfully completed a “Anti-Corruption Prevention” training module.

Incident of corruption or bribery [G1-4]

During fiscal year 2025, no Group entity was convicted or sanctioned for violating anti-corruption legislation. This statement covers convictions and related fines issued by a court during the fiscal year against Sodexo or any of its Group entities controlled by Sodexo at the time of the alleged facts. A final decision is one that is no longer subject to appeal or for which appeal deadlines have expired.