Supplier Code of Conduct

INTRODUCTION

This Supplier Code of Conduct (“Code”) sets forth Sodexo's desire to do business with those suppliers, vendors, contractors and partners (collectively referred to as “Suppliers”) that conduct business utilizing 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. This Code sets forth the minimum requirements that Suppliers must meet to do business with Sodexo. We encourage our Suppliers to ensure that this Code is communicated throughout our supply chain.

Sodexo realizes that Suppliers may need time to address areas in which they may not be in compliance. We believe that compliance is best achieved through a process of continuous improvement over a period of time.

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 re quirements, 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 and partner with Suppliers that aspire to conduct of all their business following a set of ethical standards not incompatible with our own. Sodexo's ethical standards are embodied in the company's Ethical Conduct Policy. Back to Top

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

COMMUNICATION
Suppliers are encouraged to take appropriate steps to ensure that provisions of this Code are communicated to their employees and throughout their own supply chain. Suppliers are also encouraged to ensure that the principles referred to above are adopted and applied by their employees, suppliers, agents and contractors as far as reasonably possible. Back to Top