Universal Registration Document Fiscal 2025

SODEXO ENVIRONMENTAL IMPACT	Risk level: medium
SODEXO ENVIRONMENTAL IMPACT Adverse environmental impact from Sodexo’s activities: ineffective actions to mitigate climate disruption, poor management of food waste and resources.
SODEXO ENVIRONMENTAL IMPACT Category: Sustainability
SODEXO ENVIRONMENTAL IMPACT Impact Ineffective climate disruption actions could result in Sodexo’s carbon emissions staying the same or even increasing. Given its large footprint, this could have a significant impact on global warming and biodiversity loss. In addition, this could impact our client retention, investors’ confidence and external trust and recognition. Poor food waste and resource management could result in a loss of client and consumer confidence and a decreased ability to attract new clients.	Risk level: medium Examples of mitigating activities Partnership with WWF since 2010 focused on reducing the Company’s environmental impact, achieving its carbon reduction target and managing its Sustainability strategy. Measurement and tracking of Sodexo activities carbon footprint (upstream and downstream) at site level. Designing new recipes to ensure that 70% of Sodexo main dishes are labelled low-carbon by 2030 (0.9kg CO₂e or less). Member of the Climate Group’s RE100 initiative with a commitment to switching to 100% renewable electricity by 2025 at directly operated sites. Developing and deploying a carbon trajectory tool with partner Traace to help Sodexo teams create their carbon reduction roadmap. Deploying the WasteWatch global program to reduce food waste at scale. Implementing a long-term incentive plan, including a sustainability index.

SODEXO ENVIRONMENTAL IMPACT

Risk level: medium

Adverse environmental impact from Sodexo’s activities: ineffective actions to mitigate climate disruption, poor management of food waste and resources.

Category: Sustainability

Impact

Ineffective climate disruption actions could result in Sodexo’s carbon emissions staying the same or even increasing. Given its large footprint, this could have a significant impact on global warming and biodiversity loss. In addition, this could impact our client retention, investors’ confidence and external trust and recognition.
Poor food waste and resource management could result in a loss of client and consumer confidence and a decreased ability to attract new clients.

Examples of mitigating activities

Partnership with WWF since 2010 focused on reducing the Company’s environmental impact, achieving its carbon reduction target and managing its Sustainability strategy.
Measurement and tracking of Sodexo activities carbon footprint (upstream and downstream) at site level.
Designing new recipes to ensure that 70% of Sodexo main dishes are labelled low-carbon by 2030 (0.9kg CO₂e or less).
Member of the Climate Group’s RE100 initiative with a commitment to switching to 100% renewable electricity by 2025 at directly operated sites.
Developing and deploying a carbon trajectory tool with partner Traace to help Sodexo teams create their carbon reduction roadmap.
Deploying the WasteWatch global program to reduce food waste at scale.
Implementing a long-term incentive plan, including a sustainability index.

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COMPLIANCE WITH LAWS AND REGULATIONS	Risk level: medium
COMPLIANCE WITH LAWS AND REGULATIONS Risk of non-compliance with a wide variety of laws, including labor law, anti-corruption law, data protection and privacy, and health, safety and environmental law.
COMPLIANCE WITH LAWS AND REGULATIONS Category: External Environment
COMPLIANCE WITH LAWS AND REGULATIONS Impact The wide range of services that Sodexo proposes and its worldwide presence means that it is subject to very specific laws and regulations for its operations at both the global and local level. For example, as a food operator, Sodexo has a legal requirement to provide accurate allergen information about the food and drinks it serves. Changing regulatory scenarios that also have an impact on its business include anti-corruption laws, human rights regulations, and sustainability regulations such as the Corporate Sustainability Reporting Directive (CSRD). Any non-compliance of Sodexo with laws and regulations or a lack of knowledge and awareness of laws and regulations either at a country level or a global level could mean: harm to employees, clients and consumers; damage to Sodexo’s reputation; potential financial penalties; criminal action being brought against the Company and its Directors.	Risk level: medium Examples of mitigating activities Deployment of Legal teams at both central and local levels to support operational teams. Legal teams organized by areas of expertise, with access to external experts when needed. Monitoring of the political, social and economic environments at global and country level to proactively identify proposed changes in laws that could impact Sodexo. Group-wide mandatory training sessions for Sodexo managers in regulatory areas like anti-corruption and data protection. Global Ethics and Compliance Committee ensures coordination and coherence of deployment of ethics and compliance programs amongst countries. Details of these programs are provided in sections 2.2.4.1 "Business Conduct" and 6.4 "Vigilance Plan". Sodexo Speak Up offers Sodexo employees and partners a confidential way to report illegal or unethical behavior or breaches of the Code of Conduct. Dedicated CSRD team to support the implementation of sustainability reporting in line with the directive.

COMPLIANCE WITH LAWS AND REGULATIONS

Risk level: medium

Risk of non-compliance with a wide variety of laws, including labor law, anti-corruption law, data protection and privacy, and health, safety and environmental law.

Category: External Environment

Impact

The wide range of services that Sodexo proposes and its worldwide presence means that it is subject to very specific laws and regulations for its operations at both the global and local level. For example, as a food operator, Sodexo has a legal requirement to provide accurate allergen information about the food and drinks it serves.

Changing regulatory scenarios that also have an impact on its business include anti-corruption laws, human rights regulations, and sustainability regulations such as the Corporate Sustainability Reporting Directive (CSRD).

Any non-compliance of Sodexo with laws and regulations or a lack of knowledge and awareness of laws and regulations either at a country level or a global level could mean:

harm to employees, clients and consumers;
damage to Sodexo’s reputation;
potential financial penalties;
criminal action being brought against the Company and its Directors.

Examples of mitigating activities

Deployment of Legal teams at both central and local levels to support operational teams.
Legal teams organized by areas of expertise, with access to external experts when needed.
Monitoring of the political, social and economic environments at global and country level to proactively identify proposed changes in laws that could impact Sodexo.
Group-wide mandatory training sessions for Sodexo managers in regulatory areas like anti-corruption and data protection.
Global Ethics and Compliance Committee ensures coordination and coherence of deployment of ethics and compliance programs amongst countries. Details of these programs are provided in sections 2.2.4.1 "Business Conduct" and 6.4 "Vigilance Plan".
Sodexo Speak Up offers Sodexo employees and partners a confidential way to report illegal or unethical behavior or breaches of the Code of Conduct.
Dedicated CSRD team to support the implementation of sustainability reporting in line with the directive.

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CLIMATE DISRUPTION EXPOSURE	Risk level: medium
CLIMATE DISRUPTION EXPOSURE Risk of Sodexo’s business being adversely affected by climate disruption.
CLIMATE DISRUPTION EXPOSURE Category: External Environment
CLIMATE DISRUPTION EXPOSURE Impact The risk assessment carried out in Fiscal 2022 using the Task Force on Climate-Related Financial Disclosures (TCFD) framework identified that Sodexo’s Food business had the greatest exposure to climate disruption. This risk assessment is presented in detail in section 2.2.2.1. For example, the increased frequency and severity of drought could mean that the agricultural industry becomes less productive, reducing its ability to meet demand and increasing costs. This would mean that Sodexo might not be able to source the products needed for client and consumer offers, resulting in reputational damage, or the products can only be bought at a much higher price, leading to loss of profitability on contracts. As an example of transition risk, the risk assessment highlighted a risk from a shift in consumer demand – such as a move away from traditional menus and recipes to more plant-based options. If Sodexo is not able to adapt to this change, then it will lose client and consumer business, resulting in a loss of revenues and profitability.	Risk level: medium Examples of mitigating activities Broad range of suppliers identified and utilized. Adaption of menus to take account of the availability of products and their impacts. Launch of the Future Food Collective, a collaborative initiative bringing Sodexo chefs together with industry experts and key suppliers to look at consumer habits. By partnering with NGOs such as the Food for Climate League, the Future Food Collective is gathering insights to develop new plant-based innovative solutions for consumers. Development of sustainable and healthy recipes. Roll-out of low-carbon recipes in units using ingredients selected for their lower environmental impact and higher nutritional value, including plant-based and plant-forward recipes. Deployment of Energy solutions to clients to increase energy savings and reduce their carbon footprint.

CLIMATE DISRUPTION EXPOSURE

Risk level: medium

Risk of Sodexo’s business being adversely affected by climate disruption.

Category: External Environment

Impact

The risk assessment carried out in Fiscal 2022 using the Task Force on Climate-Related Financial Disclosures (TCFD) framework identified that Sodexo’s Food business had the greatest exposure to climate disruption. This risk assessment is presented in detail in section 2.2.2.1.

For example, the increased frequency and severity of drought could mean that the agricultural industry becomes less productive, reducing its ability to meet demand and increasing costs. This would mean that Sodexo might not be able to source the products needed for client and consumer offers, resulting in reputational damage, or the products can only be bought at a much higher price, leading to loss of profitability on contracts.

As an example of transition risk, the risk assessment highlighted a risk from a shift in consumer demand – such as a move away from traditional menus and recipes to more plant-based options. If Sodexo is not able to adapt to this change, then it will lose client and consumer business, resulting in a loss of revenues and profitability.

Examples of mitigating activities

Broad range of suppliers identified and utilized.
Adaption of menus to take account of the availability of products and their impacts.
Launch of the Future Food Collective, a collaborative initiative bringing Sodexo chefs together with industry experts and key suppliers to look at consumer habits. By partnering with NGOs such as the Food for Climate League, the Future Food Collective is gathering insights to develop new plant-based innovative solutions for consumers.
Development of sustainable and healthy recipes.
Roll-out of low-carbon recipes in units using ingredients selected for their lower environmental impact and higher nutritional value, including plant-based and plant-forward recipes.
Deployment of Energy solutions to clients to increase energy savings and reduce their carbon footprint.

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Universal Registration Document Fiscal 2025

6 Risk Management