Sodexo has established a structured due diligence process to identify, assess, prevent, and mitigate actual and potential negative impacts linked to its operations and value chain. This process, which is detailed in section 6.4 Vigilance plan of this document, is aligned with international standards, including the United Nations Guiding Principles on Business and Human Rights and the OECD Guidelines for Multinational Enterprises, and is embedded across Group functions and geographies.
The process combines:
Oversight of the due diligence framework lies with the Sodexo Board of Directors, supported by the Board Sustainability Committee and the internal Ethics and Compliance Committee, while day-to-day coordination is managed by Group ethics, human rights, and sustainability functions.
This governance ensures that due diligence is not a one-off exercise but a continuous process of identification, prevention, mitigation, and remediation, integrated into Sodexo’s decision-making and strategy.
Sodexo's risk management and internal control systems relating to sustainability reporting form an integral part of Sodexo's risk management framework, outlined in detail in Chapter 6.
Sodexo's risk management framework is organized according to the "Three Lines of Defense" model, with operational managers acting as the first line of defense, and managing risks directly in operations. They are supported in their efforts by second line of defense functions (for example Supply Management, Sustainability, Human Resources, Health & Safety). Internal Audit form the third line of defense, and they undertake regular assessments of the effectiveness of the risk management and internal control systems.
Sustainability risks have been embedded in Sodexo's risk universe since 2018 and are regularly assessed in the main operational risk assessment, as well as specialized human rights and corruption risk assessments.
Sodexo's standard risk assessment approach and methodology for all risk assessments is outlined in sections 6.2.3 and 6.2.4 respectively. Existing risk criteria and risk evaluation grids were used as a basis for the double materiality analysis conducted in Fiscal 2024.
In this first year of reporting, Sodexo established a dedicated CSRD team bringing together expertise in sustainability, finance, internal control, and project management. This team coordinated the reporting process with all key stakeholder functions, while providing guidance, training, and ongoing support.
As part of the reporting cycle, the CSRD team carried out detailed process walkthroughs with each function to map data collection flows and assess potential vulnerabilities. These walkthroughs, combined with regular exchanges with reporting teams and external auditors, led to the identification of four main risk areas: (1) availability of data for certain data points, (2) reliability of data, (3) possible errors in the calculations of quantitative data, particularly manual data (4) incomplete coverage of data points.
To mitigate these risks, Sodexo has already implemented a set of structured actions and controls, including:
These measures provide the foundation for Sodexo’s sustainability reporting controls. Looking ahead, additional controls will be introduced in Fiscal 2026 as reporting systems and processes mature. A culture of continuous improvement is fostered through regular dialogue and experience-sharing between the CSRD team and teams in charge of reporting, ensuring risks and weaknesses are identified early and addressed promptly.
The CSRD team maintains regular communication with Sodexo’s governance bodies to ensure transparency and oversight of the reporting process. Progress, challenges, and identified risks are systematically reported to the CSRD Steering Committee, including updates on the development and effectiveness of internal controls.
Beyond operational governance, the CSRD Program Director and the Group Internal Control Director provide regular briefings to Sodexo’s Audit Committee.
These updates cover the advancement of the sustainability reporting process, the status of risk mitigation measures, and the continuous reinforcement of data reliability. This structured reporting ensures that both management and supervisory bodies remain fully informed and engaged, and that sustainability reporting is subject to the same rigor and scrutiny as financial reporting.
