Supplier Code of Conduct

INTRODUCTION
This Supplier Code of Conduct (“Code”) sets forth Sodexo's expectation of suppliers, vendors, contractors and others with whom Sodexo conducts business (collectively referred to as “Suppliers”) with respect to sound and responsible ethical, social and environmental practices. Sodexo recognizes that there are different legal and cultural environments in which Suppliers operate throughout the world. Regardless, this Code sets forth the minimum requirements that Suppliers must meet to do business with Sodexo. In order to comply with these requirements, Suppliers should communicate the principles of this Code throughout their supply chain.

Covered in this Code of Conduct:

1. Child Labor
2. Forced Labor
3. Wages and Benefits
4. Working Hours
5. Health and Safety Guidelines
6. Freedom of Association
7. Non-discrimination
8. Disciplinary Practices/Coercion
9. Environment Guidelines
10. Community Involvement
11. Ethical Standards
12. Conflicts of Interest
13. Communications

SODEXO SUPPLIER CODE OF CONDUCT:

CHILD LABOR
Suppliers are prohibited from using workers under the legal age of employment in any country or local jurisdiction where the Supplier performs work for Sodexo. If the minimum age of employment is not defined, the minimum age of employment shall be 15 years of age. In cases where minors are authorized to work, we expect our Suppliers to observe all legal requirements, particularly those pertaining to hours of work, wages, minimum education and working conditions. Back to Top

FORCED LABOR
Sodexo shall not tolerate the use of indentured, slave, bonded or other forced involuntary labor by its Suppliers. Back to Top

WAGES AND BENEFITS
Suppliers shall not pay less than the minimum wage in accordance with local laws or the prevailing market, whichever is higher. Back to Top

WORKING HOURS
Suppliers shall maintain reasonable employee work hours in compliance with local standards and applicable national laws of the countries and regions in which the Supplier does business. Sodexo requires Suppliers to comply with the statutory requirements for working hours for employees. Sodexo will not use Suppliers that, on a regularly scheduled basis, require employees to work in excess of the statutory requirements, unless those employees are properly compensated as required by applicable law. Back to Top

HEALTH AND SAFETY GUIDELINES
Suppliers must share Sodexo's commitment to providing a safe and healthy workplace and to treating employees fairly and in compliance with local laws. Health, safety and other workplace standards must meet all local laws and safety regulations. Worker housing, where provided, must meet the same standards for health and safety as those that apply in the workplace. Back to Top

FREEDOM OF ASSOCIATION
Employees of Suppliers shall be free to join organizations of their own choice. Suppliers shall respect and recognize the right of employees to join and organize associations of their own choosing, and to bargain collectively. Employees shall not be subject to intimidation or harassment in the exercise of their right to join or to refrain from joining any organization. Back to Top

NON-DISCRIMINATION
Sodexo believes that all terms of employment should be based solely on an individual's ability to do the job. Sodexo requires its Suppliers to uphold a commitment to basic principles of human rights. This means that Suppliers should not discriminate against employees in hiring, promotion, salary, performance evaluation or any other term or condition of work, on the basis of race, color, national origin, gender, gender identity, sexual orientation, religion, disability, or any other basis prohibited by law in the applicable jurisdiction. Back to Top

DISCIPLINARY PRACTICES/COERCION
Sodexo firmly believes that everyone should be treated with dignity. Suppliers shall not inflict or threaten to inflict corporal punishment or any other forms of physical, sexual, psychological or verbal abuse or harassment on any employees. Back to Top

ENVIRONMENTAL GUIDELINES
Sodexo will actively seek Suppliers that share our commitment to protecting the environment. Suppliers shall abide by all federal, state and local environmental laws. Sodexo shall favor Suppliers that work to sustain, protect and restore the environment, by such means as energy conservation, recycling and proper disposal of waste, as well as by environmental restoration. Back to Top

COMMUNITY INVOLVEMENT
Sodexo seeks to work with Suppliers that partner with local governments and communities to improve the educational, cultural, economic and social well-being of the communities in which they live and serve. Back to Top

ETHICAL STANDARDS
Sodexo seeks to identify Suppliers that conduct business with ethical standards consistent with our own.  Sodexo's ethical standards are embodied in our Ethical Conduct Policy.  Our Ethical Conduct Policy provides in part:

• Obey all relevant laws
• Treat each other fairly, with dignity and respect
• Prepare all records of financial transactions carefully and accurately
• Report financial conditions and results of operations, honestly and promptly
• Deal honestly and fairly with clients, customers, suppliers, and financial partners
• Avoid actual and potential conflicts of interest
• Avoid the improper giving and receiving of gifts
• Safeguard Sodexo's assets
• Protect Sodexo's reputation
• Separate personal political activities from Sodexo's business

• Report observed violations of legal and ethical standards.

Sodexo maintains several reporting mechanisms including a toll free reporting hotline with an option to report concerns anonymously. We encourage Suppliers to maintain reporting mechanisms, as well. Back to Top

CONFLICTS OF INTEREST
Suppliers may not give Sodexo employees any gift of value in excess of US$100 and may not bribe foreign officials or any other parties to benefit Sodexo, its employees or its business. Back to Top

COMMUNICATION
Suppliers should take appropriate steps to ensure that the principles of this Code are communicated to their employees and throughout their own supply chains. Suppliers should also take appropriate steps to ensure that the principles of this Code are adopted and applied by their employees, suppliers, agents and contractors to the extent applicable. Back to Top