Universal Registration Document Fiscal 2025

2 Sustainability at Sodexo

Following this analysis, eligible CapEx for Fiscal 2025 was assessed at 113 million euros, representing 24.2% of total CapEx, compared to 6.9% in Fiscal 2024 and 21.1% in Fiscal 2023. Denominator amounts at 466 million euros and includes additions and scope entrance of tangible and intangible assets (excluding goodwill) as well as right-of-use assets(3). This increase compared to last year is due to to a increase in right-of-use assets related to leases on buildings and vehicles between the two financial years.

Eligible Operational Expenditure (OpEx)

Operational expenditure within the meaning of the Taxonomy Regulation is limited to costs linked to direct non-capitalized research and development, direct maintenance, and renovation of Sodexo assets (including direct cost of employees), and direct short-term leases. Given that the Fiscal 2025 operational expenditure of 1,343 million euros was less than 10% of Group operating expenses (representing 23,094 million euros as described in the 4.2.1 note of the consolidated financial statements), Sodexo has used the exemption provided in the regulation and has not published the performance indicator for eligible OpEx.

Alignment analysis

An accordance with the criteria stipulated in the Taxonomy, alignment requires to comply with:

  • Generic DNSH;
  • Substantial contribution criteria and specific DNSH;
  • Minimum safeguards.
Generic DNSH, specific DNSH and substantial contribution criteria

With regards to generic DNSH, the analysis of climate risks that was carried at Group level (refer to section 2.2.2.1 Climate change (E1) of the sustainability statement) did not address the specificities of the activities considered eligible within the meaning of the Taxonomy, which represents only 2.3% of consolidated revenues, but mainly focused on the impact analysis on Sodexo Food and Facilities Management services doubled by a review by geography.

As a result, for Fiscal 2025, as for the previous year, Sodexo does not meet the conditions for alignment with the green taxonomy with regard to the DNSH “climate change adaptation” (Appendix A). Given the low materiality of eligible revenues, no further work has been carried out by the Group in relation to substantial contribution criteria and specific DNSH for its eligible activities.

Minimum safeguards

Review of minimum safeguards was performed at Group level through workshops held with the corresponding departments. Based on this analysis, the Group concluded that it complies with the four themes covered by the minimum safeguards:

HUMAN RIGHTS

Sodexo’s commitments to Human Rights and Fundamental Rights at Work are laid out in the Human Rights Policy and the Fundamental Rights at Work charter. Sodexo is committed to respecting human rights wherever it does business. This commitment, policies and procedures are based on international texts such as:

  1. the United Nations Guiding Principles on Business and Human Rights;
  2. the Universal Declaration of Human Rights;
  3. the International Labor Organization’s (ILO) Declaration;
  4. OECD Guidelines for Multinational Enterprises.
ANTI-CORRUPTION

Sodexo has documented its approach in the Sodexo’s Business Integrity Guide.

Specific training courses on Responsible Business Conduct are developed and delivered within the Group to the staff categories with the highest level of exposure. E-learning modules on Responsible Business Conduct (combating sexual harassment, data protection, public affairs, human rights in the workplace, and preventing corruption and conflicts of interest) have been put in place for all of the Group’s leaders and managers.

TAXATION

Sodexo Group undertakes to respect local tax laws and regulations that apply and pay its fair share of taxes in all countries where it operates, in line with the substance of the economic activity of the business locally (refer to section 6.1, paragraph Tax policy).

FAIR COMPETITION

Sodexo complies with anti-trust laws, which prohibit competitors from agreeing to fix prices, rig bids or to allocate markets, geographies or clients. Sodexo Group formalized its fair and open competition approach in the Business Integrity Guide. Initiatives are put in place to raise awareness among employees and suppliers of the importance of respecting anti-trust laws.

Synthesis and outlook for Fiscal 2026

Sodexo strictly applied the regulation and none of its eligible activity or investments was qualified as “aligned” after review of technical screening criteria and analysis required for alignment.

As detailed in section 2.1 Sustainability vision, sustainability has always been at the heart of our mission and everything we do. Despite limited Taxonomy-eligible activities today, as Sodexo's main activity is providing food services, we are convinced that our services bring positive impact to our employees, consumers, clients, suppliers, and shareholders.

Sodexo will follow the evolution of the Taxonomy reporting requirements in Fiscal 2026 and adapt its methodology and analysis, where relevant and in accordance with its sustainability strategy.