CODE OF
BUSINESSCONDUCTTHE COMPASS WAYINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPOUR FRAMEWORKOUR VISION AND VALUESOUR CODE OF BUSINESS CONDUCTOUR GROUP POLICIESOur Vision is to be a world-class provider of contractfood service and support services, renowned for our
great people, our great service, and our great results.

Our Code of Business Conduct supports us in
upholding our high ethical standards andcommitments. It sets out the principles, standards
and expectations of how we conduct business globallyand how we should engage with and treat one
another.

Our Group Policies establish the minimum
requirements and behaviours expected to support
embedding our Values and Code of Business Conduct
wherever we operate. They are mandatory and form
the foundation for local policies and practices.

Our Values set out what we collectively believe in andguide our behaviours, including our commitment to
Safety, Integrity and Respect in everything we do.

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYMESSAGE FROM DOMINIC BLAKEMORE
As a global leader in food services, Compass Group always
strives to do what’s right; for our people, our customers, ourshareholders, the planet, and the communities we serve.
To achieve this, we are committed to maintaining strong
governance and high ethical standards throughout our
global operations and to conduct business with integrity,
to never compromise on safety, and to treat others withkindness and respect.
The Group’s success and future growth depends on everyone
upholding these commitments. Because, whatever our rolein Compass, how we act and behave can affect how we areviewed and impact the trust that our stakeholders have in us.

COMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP“OUR CODE OF BUSINESSCONDUCT REFLECTS WHO WE
ARE AND PROVIDES A CLEAR
PATH – FOR EVERYONE
WORKING WITH, FOR, OR ON
BEHALF OF COMPASS – TO
ALWAYS DO WHAT’S RIGHT. ”

Our Code of Business Conduct (the “Code”) reflects who
we are and provides a clear path – for everyone working with,
for, or on behalf of Compass – to always do what’s right.
We all have a shared responsibility to understand, follow
and embed the principles, standards and behaviours set out
in the Code, which is approved by the Compass Group PLC
Board of Directors and Group Executive Committee.
Should you ever feel concerned the Code is not being
followed, please speak to your Line Manager, or submit areport through our confidential reporting programme,
Speak Up, We’re Listening.
I want to thank everyone for playing your part in putting theCode to work everywhere, every day, now and in the future.
Together, we can ensure Safety, Integrity and Respect is at
the heart of everything we do. It’s the Compass Way.

DOMINIC BLAKEMOREGroup Chief Executive Officer

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTThis Code may be amended from time totime. The most recent version of the Codeis available on Compass’ website

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYI BELIEVE
IN THE CODE
3COMPASS GROUP PLC CODE OF BUSINESS CONDUCTPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITYWE STAND
BY THE CODE

COMPANY ASSETSSPEAKUPTOGETHER, WE
LIVE OUR VALUESINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETY

WHAT IS THE COMPASS CODE OF
BUSINESS CONDUCT?
The Compass Group (“Compass”/”We”/”Our”/”Company”)
Code of Business Conduct (the “Code”) sets out the minimum
standards and behaviours we expect from everyone working foror on behalf of Compass. It guides us when there are questions
or situations where the right course of action may be unclear.
Building mutual trust and confidence in those who work for,partner with and invest in us is key to our continued success,and depends on each of us acting professionally, responsibly
and in accordance with the standards and principles set out inthis Code. By following the Code, we can protect each otherand the Company’s reputation for integrity and strong
governance.

WHO DOES THE CODE APPLY TO?
The Code applies to everyone working with, for or on behalf ofCompass, including without exception temporary and contract
staff regardless of location, role or level of seniority.

IT IS THEREFORE IMPORTANT THAT YOU
UNDERSTAND THE RULES AND
PRINCIPLES YOU MUST FOLLOW AND THE
STANDARDS AND BEHAVIOURS THAT ARE
EXPECTED OF YOU.
It is your responsibility to ensure that you have read andproperly understood the contents of the Code and associatedGroup Policies. If there is anything in the Code that you don’t
understand or are unsure of, speak to your Line Manager.
Contractors, intermediaries, representatives, joint venture
partners and companies we invest in (our “business partners”)
are expected to follow and comply with this Code. Our suppliers
are also expected to meet the standards and principles of thisCode and comply with the Global Supplier Code of Conduct.

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPVISION & VALUES
Our Vision and Values capture in words the spirit of Compass and what we stand for. They
underpin the decisions and actions of our people; are evidenced in our customers’ experienceof the service we deliver; drive our performance and will further enable sustainable growthover time.
Our Values set out what we collectively believe in and guide our behaviours.

Openness, Trust and Integrity
We set the highest ethical and professional standards. We want all our
relationships to be based on honesty, respect, fairness and a commitment toopen dialogue and transparency.

Passion for Quality
We are passionate about delivering superior food and service and take pride inachieving this. We look to replicate success, learn from mistakes and develop
the ideas, innovation and practices that will help us improve and lead ourmarket.

Win Through Teamwork
We encourage individual ownership but work as a team. We value the expertise,individuality and contribution of all colleagues, working in support of each otherand readily sharing good practice, in pursuit of shared goals.

Responsibility
We take responsibility for our actions, individually and as a Group. Every day,everywhere we look to make a positive contribution to the health and wellbeingof our customers, the communities we work in and the world we live in.

Can-do Safely
We take a positive and commercially aware “can-do” approach to theopportunities and challenges we face.

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPFIVE GOLDEN RULES
Our Five Golden Rules encapsulate the Code and provide
context to our strategic and disciplined focus on People,
Performance and Purpose as our key strategic priorities.

Health and safety is our number one priority– make sure it is your number one priority too.
Any unethical or illegal activity is strictly
prohibited including corruption, bribery,anti-competitive behaviour or fraud.
Be kind and caring. Treat each other fairly,
with respect and dignity.
Always be professional, polite, honest andtransparent when dealing with customers,
suppliers and colleagues.
Act with integrity. Don’t do anything which
could harm Compass’ reputation.

“PROTECT YOURSELF.
PROTECT COMPASS.”

5COMPASS GROUP PLC CODE OF BUSINESS CONDUCTINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

LIVING THE CODE – WHAT IS EXPECTED OF YOU?
Our words and actions must always reflect our values anddemonstrate the highest ethical standards in how we conduct
our business and engage with our customers, investors andbusiness partners.
This Code provides principles-based guidance and the
expected standards and behaviours to help do what’s right.
Our pledge is to:– uphold the standards, principles and commitments set out
in this Code and instil these within our day-to-day work
– follow all processes and procedures that are in place toensure that we adhere to applicable compliancerequirements– foster a safe, respectful and inclusive workplace withaccess to the information, training and tools needed to help
employees and colleagues adhere to the expectations inthis Code.
All employees and business partners must comply withapplicable laws and regulations. Where there is a difference
between the requirements of this Code, Group or local Policies
and applicable laws or regulations, you must apply whichever ismore stringent.
We should not engage any contractor, agent, consultant,
supplier, customer or any other third party whose businesspractices conflict with the Code. If engaging any third party to
act on behalf of Compass, it is our responsibility to always
consult the Legal team and undertake reasonable due
diligence to ensure that our values and principles align, andrisks are appropriately assessed.
Anyone found to be in breach of applicable laws or whose
actions and behaviours are inconsistent with our Code could
face disciplinary action up to and including dismissal.

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCT“OUR ACTIONSMUST ALWAYS
REFLECT OUR
VALUES.”

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYOUR ETHICAL DECISION-MAKING MODEL
Using our ethical decision-making model can help us
make the right choices. It will help determine what weshould do rather than what we can do. Doing what’s rightis always informed by the circumstances we face andmay involve going beyond what is required by law.
Because something is legal or culturally acceptable in
one jurisdiction does not necessarily make it legal inanother jurisdiction. The guiding principle will always bewhether it is ethical and in line with Compass’ values.
Before making a decision or being asked to agree with adecision made by someone else, always consider if thatdecision:PERSONAL INTEGRITYCOMMERCIAL INTEGRITYSEEKING ADVICE IS A
SIGN OF STRENGTH,
NOT WEAKNESS.

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTCOMPANY ASSETSSPEAKUP

DOING WHAT’S RIGHT | LEGAL | ETHICALUNDERPINNED BY COMPASS’ VALUES

Is free from any conflictof interest– is free from any conflict of interest– serves a legitimate business purpose– is something you believe reflects your role andresponsibilities to uphold Compass’ Values– would not harm Compass’ reputation if made public– is in line with the Code and Five Golden Rules.
If the answer is no to any of these questions, we must
pause, reconsider and seek advice from our LineManager, Legal and/or Group Ethics & Integrity before
taking any further action.

EXTERNAL ACTIVITY

Serves a legitimate
business purpose

Alwaysconsider if
the decision...

Would not harm Compass’
reputation if made public

Is in line with our Codeand 5 Golden Rules

Is something you believe reflects
your role and responsibilities touphold Compass’ Values

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETY

THE
COMPASS
WAY

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPThis includes engaging a wide range of stakeholders at a
global, country and local level who influence or are affected byour day-to-day business and aligning our sustainability strategy
with the United Nations Sustainable Development Goals,
focusing on areas where we can have the most impact.
We conduct our business in a sustainable way and we
proactively make efforts to minimise negative effects (such as
by reducing climate net zero greenhouse gas emissions) andmaximise the opportunity to contribute to positive impacts on
the environment. To this end, it is important that we promoteand encourage environmental responsibility in all areas within
our control, regardless of our position.
Compass is committed to making continuous progress on thesustainable development of the communities in which we live
and work, facilitating opportunities to support local
communities and ensuring that our commitments aretransparent, ethical and in line with our values.

For more information, refer to ourEnvironmental Policy Statement and our
Sustainability page on our website

9

COMPASS GROUP PLC CODE OF BUSINESS CONDUCT– comply with all applicable laws, regulationsand Group Policies, standards andprocedures in relation to environmental
matters– help safeguard the environment andminimise the impact of our operations– ensure energy efficiency and carbon
emissions are considered in all aspects of
our work and take steps to save energy andreduce our carbon footprint wherever
possible– work to reduce food waste in our operations
and where possible, support theredistribution of surplus food in thecommunity– actively reduce unnecessary packaging andwork to introduce sustainable alternatives
over single-use products and fossil fuelbased plastics– ensure that we are equipped with the rightinformation, training and tools necessary to
implement responsible environmental
practice– strive to support local communities,
minority groups’ businesses andorganisations including helping to develop
local skills and capabilities

DON’T

AS A LEADING INTERNATIONAL FOODSERVICE BUSINESS, WE FOCUS ON
WHERE WE CAN HAVE THE BIGGESTPOSITIVE IMPACT ON THE GLOBAL
FOOD SYSTEM, THE ENVIRONMENT
AND LOCAL COMMUNITIES.

DOSUSTAINABILITY– dispose of waste material in an illegalmanner– carry out activities that waste water– ignore our responsibilities to influencebusiness partners to contribute to positive
impacts on the environment– disregard indigenous peoples’ rights or land
rights– grant community support to improperly
influence a business decision– publish, authorise or disclose sustainability
data or information that is inaccurate, false
or misleading– publish, disclose or release non-publicsustainability data or information without
appropriate approvals in accordance with
the Group Approvals Manual (internal only)
and/or Group or local Policies

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPWe are committed to the OECD Guidelines for Multinational
Enterprises, the United Nations Guiding Principles on Businessand Human Rights, the core conventions of the International
Labour Organisation and Ethical Trading Initiative Base Code.
We are a signatory of the United Nations Global Compact andrespect its principles, which means wherever we work in theworld, we will always seek to respect and uphold thefundamental Human Rights and freedoms of everyone whoworks for or with us, and of the people and communities wework among.

WE HAVE ZERO TOLERANCE TO FORCEDLABOUR AND ARE COMMITTED TO
PLAYING OUR PART TO ERADICATE
MODERN SLAVERY AND HUMAN
TRAFFICKING IN ALL ITS FORMS.

For more information, refer to our Human
Rights Policy and our Modern Slavery and
Human Trafficking Statement

10

COMPASS GROUP PLC CODE OF BUSINESS CONDUCT– comply with local legal requirements inrelation to all types of employment
arrangements, including but not limited topermanent, short-term, casual or agency
employees and workers– follow and uphold the principles of our
Human Rights Policy– treat every employee and/or worker fairly
and with dignity and respect, regardless of
their background, which includes but is not
limited to race, sex, colour, origin, ethnicity,religion, beliefs, age, disability, sexual
orientation, gender identification or
expression, political opinion or social
background– provide transparent, fair and confidential
procedures for our employees to raise
relevant concerns. These must enable
employees to discuss any situation where
they believe they have been discriminatedagainst, harassed or treated unfairly or
without respect or dignity– continue to promote the principles ofrespecting human rights and seek to further
raise awareness of modern slavery andhuman trafficking risks throughout our
supply chains– respect indigenous peoples’ rights or land
rights

DON’T

We respect the human rights and dignity of people throughout
our operations and global supply chains, including thoseconsidered as belonging to “vulnerable” groups. We comply
and expect our suppliers to comply with all applicable local
laws including those that promote decent, safe working
conditions and individual security; laws prohibiting forced andchild labour; prohibitions on human trafficking; and laws thatsafeguard freedom of association and the right to engage incollective bargaining.

DO

HUMAN RIGHTS AND MODERN SLAVERY– use, benefit from or permit to be used,
forced or compulsory or trafficked labour– use, benefit from or permit to be used any
form of child exploitation– support the charging of any fees or costs forrecruitment of cross-border migrant workers
to ensure alignment with the employer pays
principle– engage in any direct behaviour that isoffensive, intimidating, malicious or
insulting. This includes any form of sexual orother harassment or bullying, whether
individual or collective and whether
motivated by race, age, role, gender
identification or expression, identity, colour,
religion, ethnicity, country of origin, sexual
orientation, marital status, dependents,
disability, social class or political views– assume someone else will, or ignore ourpersonal responsibility to, report a potential
human rights incident or issueINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPCOMPASS IS COMMITTED TO EQUALITY,WELLBEING, INCLUSION AND FAIRNESSFOR ALL OUR EMPLOYEES. WE AREOPPOSED TO ANY AND ALL FORMS OFDISCRIMINATION, BULLYING OR
HARASSMENT.
We also expect our business partners to uphold practices ofzero tolerance to discrimination in respect to employment andoccupation, and fostering an environment of diversity, equity
and inclusion.
Compass takes a holistic approach to ensure people feel
respected, including but not limited to their background, race,
sex, gender identification or expression, identity, age, sexual
orientation, religion, ethnicity, marital or civil partnershipstatus, pregnancy or maternity or disability.

For more information, refer to ourDiversity, Equity & Inclusion Policy andCompass Commitments

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

We are committed to hiring, developing and retaining diverse
talent which reflects the communities in which we live andwork. We are dedicated to encouraging a supportive, respectful
and inclusive culture where colleagues are welcomed, can bethemselves and feel that they belong.

– comply with all applicable local laws,
regulations and labour standards– treat people equitably, fairly and without
discrimination– put in place and promote ethical, positive,
safe and fair working conditions– ensure that all work is based on a legally
recognised employment relationship andthat employees and workers receive clear
written information about their employment
terms and benefits– make all employment decisions, including
hiring, promotion, training and transfers
solely based on merit, aptitude and ability
and in compliance with relevant local laws,
regardless of the work arrangement type
– recognise and be sensitive to behaviours
that might be acceptable to some cultures,backgrounds or perspectives but not toothers and adjust such conduct as may bereasonable and/or necessary– make appropriate, reasonable adjustments
as necessary to support those who need it(e.g. adjustments of working arrangements
for those with a disability, for those withcaring responsibilities etc.)

DON’T

EMPLOYMENT AND INCLUSION– hire any individual younger than 15 years
old or the local legal minimum age
requirement, whichever is higher– tolerate any form of harassment, bullying,
discrimination, hostile, offensive,
intimidating, malicious, insulting or
degrading treatment, whether physical,
verbal, sexual, or any harmful acts including
violence or threats of violence– engage in any direct behaviour that is
hostile, offensive, intimidating, malicious,
insulting or degrading towards a specificindividual or individuals. This includes
whether done individually or collectively
with others– engage in any indirect behaviour which isoffensive, intimidating, malicious, insulting
or degrading towards a specific individual orindividuals, and/or could be construed asharassment or bullying

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP

Where possible, we source ingredients from suppliers local to
our units, purchase seasonal and organic produce andparticipate in fair trade initiatives. We place great emphasis on
responsible sourcing.
The chemicals and other products we buy and use to support
the delivery of our services are responsibly sourced andtransported to ensure our people and customers are notunnecessarily exposed to risk.
We recognise the importance of maintaining both visibility andtransparency within our supply chains to maximise positive
impact and also to protect those who work within it frompotential abuse and exploitation.
We are committed to continuously seeking to influence andraise animal welfare standards throughout our global supply
chains.

You can find more information about
our work with suppliers by reading our
Global Supplier Code of Conduct, ourSupply Chain Integrity Policy Statement
and our Responsible Sourcing page on
our website

12

COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

WE ARE COMMITTED TO SOURCINGOUR PRODUCTS AND SERVICES IN ASUSTAINABLE, ETHICAL AND
SOCIALLY CONSCIOUS WAY.

– comply with all applicable laws andregulations in relation to our sourcing andprocurement activities– continue to embed the principles of our
Global Supplier Code of Conduct throughout
our supply chains– conduct appropriate due diligence toensure that, from supplier onboarding
through to supply and payment, therelationship is conducted in accordancewith the guiding principles of this Code andGroup and/or local Policies– promote improving animal welfare wherever
we can have a positive impact in our supply
chains– support diversity, equity and inclusion
focused suppliers wherever possible– respond to red flags in relation to ethicalsupply chain risks in a timely way

DON’T

RESPONSIBLE SOURCING– compromise ethical values, standards,
behaviour, quality or safety in our
engagements with suppliers– take the easy or convenient option tocontinue doing business with a supplier or
distributor (or indirectly their supplier). This
includes in circumstances when it is not theright thing to do or in the event of
unsatisfactory progress being made to
remediate an issue or non-compliance with
the Code or our Global Supplier Code of
ConductINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYHEALTHAND
SAFETY

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPWE PROMOTE ROBUST WORKPLACE
SAFETY AND QUALITY STANDARDSTHROUGHOUT OUR OPERATIONSAND EXPECT THE SAME FROM OUR
BUSINESS PARTNERS.
We strive to continuously improve our health and safety
performance and regularly measure compliance against ourstandards to assure our customers and others who work withus that we are operating the safest environment possible.

For more information, refer toour Workplace Health & Safety
Policy Statement

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

Our commitment to zero harm stems from our caring andinclusive culture whereby the health, safety and wellbeing of
our employees, workers, customers and the communities weserve are our top priority.

– comply with all applicable laws andregulations, and adhere to relevant industry
standards on workplace health and relevant
safety rules and procedures– seek to prevent injury to any employee,customer, on-site supplier or contractor– stop unsafe work immediately– follow and adhere to Group and local
workplace health and safety Policies,
standards and procedures– ensure that employees are competent,
appropriately trained and provided withappropriate personal protective equipment
to safely perform their work
– ensure we only undertake work that we aretrained, competent, capable and medically
fit to do– promptly report any actual or near missinjury, ill health, unsafe or hazardous
condition that is related to our work or
ability to perform our duties– investigate and conduct a root-cause
analysis of all serious incidents and nearmisses– share lessons learned with our colleagues tohelp prevent reoccurrence of incidents– review health and safety policies regularly toensure that they are kept up to date withlegislative and regulatory requirements andleading practice

DON’T

WORKPLACE HEALTH AND SAFETY– ignore an unsafe act or hazard. If weobserve someone else performing an unsafe
or hazardous act, we should explain to that
person why it is unsafe, ask that they stopand follow local procedures to remediate
the issue– come to work or undertake any work-related
activity whereby our ability to perform afunction or duty safely is impaired by drugs,
alcohol or other substances– perform a task or function that we are notappropriately trained for or capable ofundertaking in a safe and compliant manner– allow a team member to continue working
whilst impaired or to perform a task orfunction that is unsafe or non-compliant– assume someone else will report an unsafe
or hazardous situation

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPTo ensure safe and effective practice, we have developed a setof common minimum operating standards and behaviours
which must be practiced at every location where we operate.
These are underpinned by regulatory requirements and leadingindustry practice.

For more information, refer to ourFood Safety Policy Statement

15

COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDOOUR PRIORITY IS TO SERVE FOOD TO OUR
CUSTOMERS THAT IS PREPARED TO THE
VERY HIGHEST STANDARDS USINGQUALITY PRODUCTS AND INGREDIENTS.

– comply with all applicable laws andregulations and all Company food safety
frameworks, policies and procedures– handle, prepare, store and transport foodunder appropriate and sanitary conditions
that do not expose it to the risk ofcontamination– ensure food products and ingredients are
only sourced from reputable, approved
suppliers who meet our standards– provide employees with the information,
training and tools necessary to do their job
in a safe, hygienic and compliant manner– ensure employees who provide customer
information on food allergens, intolerancesand sensitivities are appropriately trained– promptly report any actual or potential foodsafety issue and take immediate steps to
avoid risk of contamination– review food safety policies regularly toensure that they are kept up to date withlegislative and regulatory requirements andleading industry practice

DON’T

FOOD SAFETY– expose food to situations that create a riskof contamination– perform a task or function that we are notappropriately trained for or capable ofundertaking or which is not in compliancewith Company food safety frameworks,
policies and procedures– allow a team member to continue working
or to perform a task or function that is
unsafe or non-compliant with Company foodsafety frameworks, policies and procedures– shortcut or circumvent our food safety
policies, protocols or procedures, or ignore
regulatory requirements or guidance– operate a unit, food preparation kitchen or
storage facility without the required permit
or licence in accordance with local laws or
regulations– mislead a customer about the use of
products, ingredients or additives– knowingly omit ingredients or fail tohighlight allergen risks in food or beveragelabelling– assume someone else will report an unsafe
or non-compliant situation

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL
INTEGRITY

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP

Conflicts of interest arise when personal interests are placed
ahead of the interests of Compass and those personal interests
unduly influence or are perceived to influence businessjudgments, decisions or actions. In these situations, it may
make it difficult to perform work for Compass objectively, fairly
and effectively, and may have legal, regulatory and reputational
consequences.

WE SEEK TO ALWAYS ACT IN THE
BEST INTERESTS OF COMPASSAND FOR THIS REASON DISCLOSINGPOTENTIAL AND/OR ACTUAL CONFLICTS
OF INTEREST HELPS FOSTER A CULTURE
OF OPENNESS, TRUST AND INTEGRITY.

For more information, refer to ourBusiness Integrity Policy or contact Legalor Group Ethics & Integrity

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

All employees and anyone working for or with Compass are
expected to avoid having personal interests (including personal
activities and financial interests) which could conflict with their
responsibilities, duties and obligations to Compass.

– comply with all applicable laws andregulations– ensure our personal activities, interests andrelationships do not conflict with our duties
and responsibilities to Compass– report and disclose any actual, perceived or
potential conflict of interest in a transparent
and timely manner. Where a conflict cannot
be avoided, manage it appropriately andtransparently, taking advice from our LineManager, Legal or Group Ethics & Integrity– record in the applicable disclosures register
any actual or potential conflict of interest

DON’T

CONFLICTS OF INTEREST– inappropriately take or divert to others any
business opportunities for personal gain or
to further or benefit a personal relationship– misuse our position or authority at Compass
to advance our personal interests or thoseof friends or family or individuals/organisations personally known to us– accept appointments, debate, vote, or
participate in any decision-making process
or activity when a conflict of interest exists
or might arise that involves us

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPWe ensure that only employees or authorised third parties, witha genuine business need, have access to confidential
information.
Our customers, employees, business partners andstakeholders expect us to maintain strict controls on theconfidential information we hold or use. Sharing or using
confidential information incorrectly can have serious
consequences, including significant fines and penalties,
criminal charges, civil action and loss of trust.
Confidential information includes electronic or documentary
information in relation to matters such as products orprocesses, about our customers and suppliers, vendor lists,
pricing, marketing or service strategies, non-public financial
reports, policies or procedures, information on asset sales,
mergers and acquisitions. This list is not exhaustive.
Inside information is also a form of confidential information andhas a meaning defined by law. It is information of a precise
nature, which has not been made public, that relates directly or
indirectly to Compass Group which, if it were made public,
would be likely to have a significant effect on the price ofCompass Group securities. Dealing in Compass Groupsecurities while in possession of inside information is a criminal
offence in the UK, US and many other countries.

For more information, refer to our Share
Dealing Code (internal only) or contact
the Group Company Secretariat

18

COMPASS GROUP PLC CODE OF BUSINESS CONDUCT– comply with all applicable laws
and regulations– adhere to our Share Dealing Code where
you have been advised you are a restrictedperson or placed on a project or aninsider list
– ensure confidential information or
inside information is only disclosed on aneed-to-know basis and with specificauthority to do so– take care when handling or using
confidential or inside information– remain aware that using inside information
to deal in securities; recommending,encouraging or inducing somebody else todeal; or disclosing inside information(except where you are required to do so as
part of your employment or duties) could
give rise to a breach of insider dealing laws,
which can amount to a criminal offence– take care not to disclose confidential orinside information in public places,
including taking all necessary steps toprotect information in documents andon technology devices away fromthe workplace– seek advice if we are unsure what isconfidential or inside information orwhether any activities could lead to insider
dealing risks

DON’T

WE ARE COMMITTED TO PROTECTING
ALL CONFIDENTIAL INFORMATIONAND ONLY DISTRIBUTING OR SHARING
IT ON A NEED-TO-KNOW BASIS WITH
THE NECESSARY APPROVALS.

DOCONFIDENTIAL AND INSIDE INFORMATION– copy, disclose or use any confidential
or inside information for personal gainor advantage– copy, share or use confidential or inside
information with anyone else, including
relatives, friends or colleagues who do notneed to know
– disclose or share confidential or inside
information (including to internal
stakeholders or colleagues) without specificauthority, or prior to release of trading
updates or other market announcements– buy, sell or otherwise deal in Compass
shares (or those of any other listedcompany) if we are in possession of inside
information. We should not ask other people
to trade on our behalf or confide in others
the inside information that we have– copy or take confidential information with us
if our employment with Compass ends
– share confidential or inside information in
an unsafe or insecure manner. If unsure
what transfer mechanism provides
adequate protection, seek guidance from
Digital & Technology

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP

Antitrust, antimonopoly and competition laws (“competition
laws”) protect consumers and promote fair competition byprohibiting any coordinated action between market
participants to fix or artificially adjust prices, divide markets, orshare customers, limit production or supply, rig bids orotherwise restrict trade. The sharing of commercially sensitive
information with competitors (directly or via a third party) is
also prohibited. Anti-competitive conduct, including pricefixing involving companies operating at different levels of the
supply chain is also prohibited. Competition laws are designed
to ensure that businesses compete fairly and do not prevent,
restrict or distort competition (or have the intention of doing so)to provide quality goods and services at fair prices.

WE PROMOTE FAIR COMPETITION
AND MAINTAIN THE TRUST OF OUR
CUSTOMERS, BUSINESS PARTNERS,INVESTORS AND THE GLOBAL BUSINESSCOMMUNITY BY UNDERSTANDING ANDCOMPLYING WITH APPLICABLE
COMPETITION LAWS.
This includes rejecting participation or otherwise engaging in
cartel-related activity with competitors or other third parties
who might be coordinating bids or tenders.

For more information, refer to ourBusiness Integrity Policy or contact Legalor Group Ethics & Integrity

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

We are committed to competing fairly, globally.

– comply with competition laws for all
categories and markets in which we operate– ensure that our business relationships withcustomers and business partners areproperly documented and approved byLegal– exercise caution and obtain relevant
approval when participating in a tradeassociation, trade conference or otherindustry forum to ensure we do not engage(actively or passively) in any anticompetitive behaviour– seek legal advice if intending to collaborate
with competitors or suppliers in relation toindustry, environmental, sustainability orother governance initiatives to ensure any
agreement does not restrict or have anegative effect on competition– seek legal advice in advance if intending toenter into a supply or other commercial
agreement with a competitor– notify Legal or Group Ethics & Integrity or
submit a report through Speak Up, We’re
Listening as soon as possible should you
become aware of any activities or third party
arrangements that could give rise toanti-competitive practices

DON’T

FAIR COMPETITION– rig bids or tenders or have communication
with competitors or other third parties inrelation to any bids or tenders (except, forinstance, in connection with an official joint
bid or joint venture being dealt with by yourlocal Legal team)– share commercially or competitively
sensitive information directly or indirectlywith competitors unless such arrangements
have been approved by Legal– agree or even discuss with competitors
pricing, including the price at which
Compass sells or intends to sell goods orservices, or any other financial or nonfinancial commercial strategies– attempt to dictate to customers the price atwhich they resell goods or services supplied
to them by Compass, where applicable– agree with any other company to limit the
production of goods or the supply ofservices, or to divide markets or customers
with them or to collectively boycott a market
participant– automatically adopt suppliers’
recommended retail prices. We shouldmake our own pricing decision and record it

INTRODUCTION

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP

Corruption is an abuse of entrusted power. Its impact onsociety and communities is damaging. Bribery occurs whensomeone directly or indirectly offers, promises rewards or gives
to or accepts or requests a financial or other advantage fromanyone, intending that the person receiving the benefit
improperly performs their duties or obligations.
An advantage can include anything of value such as money,
gifts, hospitality, favours, improper signing bonus or rebates,
donations, sponsorships or community investments. It could
also include non-monetary benefits or an opportunity, such as
the promise of employment for a family member or closefriend.
As a signatory to the United Nations Global Compact, we arecommitted to work against corruption in all its forms, including
extortion and bribery.

ANY UNETHICAL OR ILLEGAL ACTIVITY
IS STRICTLY PROHIBITED.

For more information, refer to ourBusiness Integrity Policy, Group
Approvals Manual (internal only)or speak to Legal or Group
Ethics & Integrity

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

We are committed to upholding the highest standards ofintegrity and professionalism in everything we do.

– comply with all applicable anti-corruption
laws and regulations– act with integrity in order to protect
Compass’ reputation and ensure thelong-term success of our business– reject any demand for, or offer of, a bribe– obtain management approval and seek
legal advice in advance when offering,
giving or accepting an advantage inconnection with a business transaction ordeal– ensure those acting on our behalf or
performing services for us share our values
and principles and work with integrity– exercise extra care when dealing withgovernment officials or third parties
interacting with or representing government
officials including those performing services
on Compass’ behalf– seek prior approval before offering or
accepting any gifts or hospitality, in
accordance with Group and local Policies
and procedures– ensure charitable donations, in-kind
donations, sponsorships and community
investments are used in line with Compass’
Business Integrity Policy and corporatesocial responsibility objectives– notify Legal, Group Ethics & Integrity or
submit a report through Speak Up, We’re
Listening as soon as possible should you
become aware of any activities or third party
arrangements that could give rise to bribery
and corruption

DON’T

COUNTERING BRIBERY AND CORRUPTION– offer, accept or pay bribes in any form, nomatter where we operate, no matter what
the situation is, and no matter who is
involved– give or offer facilitation (grease) or othersweetener payments, unless faced with asituation where your personal safety isthreatened if you refuse to make payment– give improper payments of cash (or cash
equivalents) including inappropriately
paying someone else’s personal bills or
expenses– provide any advantage or benefit togovernment officials to influence decisionmaking– allow or otherwise authorise ourconsultants, advisors, agents orintermediaries to pay bribes directly or
indirectly– offer, give or accept any advantage,
regardless of value, which might beconstrued as influencing a businessdecision

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUP

These activities are damaging to global communities aroundthe world.
Compass complies with applicable sanctions and trade control
programmes. Sanctions programmes are put in place bygovernments and intergovernmental organisations that prohibitor restrict transactions by or with certain individuals, entities,
sectors and/or countries (“sanctioned activity”). Compass aims
to take effective and necessary precautions to ensure we do
not engage in sanctioned activity that would violate law or
unnecessarily expose us to reputational risk.
Money laundering is the effort made to hide or disguise theproceeds of crime and keep them in criminal hands.
Terrorist financing includes receiving or providing money orproperty where it’s intended or potentially used for the
purposes of terrorism or laundering terrorist property.
Tax evasion is the illegal non-payment or underpayment of tax
anywhere in the world. It involves knowingly helping anotherperson commit tax evasion or otherwise being complicit in theiractions.
Compass strictly prohibits doing business in a way that assists
or facilitates such crimes wherever we operate.

For more information, refer to ourBusiness Integrity Policy or contact Legalor Group Ethics & Integrity

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

WE ARE COMMITTED TO HELPING IN
THE GLOBAL FIGHT AGAINST MONEY
LAUNDERING, TERRORIST FINANCING
AND TAX EVASION.

– comply with all applicable laws andregulations– understand and apply the procedures andcontrols in place to prevent and detect theconcealment of illegal or illicit funds– undertake reasonable checks in relation tofinancial transactions with business
partners in order to ensure we do notreceive the proceeds of criminal activities orengage in sanctioned activity, as this canamount to a criminal offence– remain alert to red flags regarding tax
evasion, notably the purpose and method of
payment, recipient and location of bankaccounts– stay vigilant when processing invoices andpayments and receiving or receipting funds,
ensuring irregularities are addressed or
escalated in a timely manner– notify Legal, Group Ethics & Integrity
immediately or submit a report throughSpeak Up, We’re Listening as soon as
possible if we have any suspicions about
actual or potential money laundering,terrorist financing, tax evasion or sanctions
breaches

DON’T

OTHER ECONOMIC CRIME COMPLIANCE– under no circumstances, knowingly enter
any form of commercial or otherarrangement that involves illegally acquired
funds or assets, or that results in thefinancing of terrorism or engaging insanctioned activity– knowingly engage a counterparty who isconnected to organised crime or othercriminal activity– accept, receive, offer or give unusual cashtransactions outside the ordinary course ofbusiness unless approved at the appropriate
level by Legal and Finance– simply assume reasonable third party
checks have been undertaken. Failure tocheck may put Compass and its employees
at risk– issue payments to a third-party bankaccount that is not located in a jurisdiction
where the third party operates, isheadquartered or where the goods orservices originated from or are delivered toINTRODUCTION

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COMPANY ASSETSSPEAKUPEngaging in any fraudulent, misleading or dishonest behaviour
is strictly prohibited.
Everyone involved in creating, processing, and recording
information in Compass’ financial books and records is held
responsible for ensuring the integrity of the information.
Our books and records must accurately reflect our financial
and business transactions in accordance with our applicableaccounting standards and our system of internal controls.

For additional information, refer to theGroup Approvals Manual (internal only),
Business Integrity Policy or contact Group
Finance or your country finance team

23

COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDOWE BELIEVE IN CONDUCTING BUSINESS IN
AN HONEST AND TRANSPARENT WAY.

– comply with all applicable laws andaccounting standards– follow and comply with our system ofinternal controls– ensure that all accounting records, financial
reports and statements present inreasonable detail a complete, fair andaccurate view of our businesses’ financial
health– ensure the Group Approvals Manual andlocal processes are adhered to andappropriate documentation is submitted tosupport submissions and approval requests– ensure transactions we approve and record
are supported by a legitimate businesspurpose– retain accounting records anddocumentation in accordance with local
tax, financial and legal obligations

DON’T

ACCURATE FINANCIAL BOOKS AND RECORDS– withhold or falsify any record, financial or
non-financial, or mischaracterise anytransaction to conceal its true nature,
purpose and/or recipient– create, maintain or authorise others to
improperly produce or maintain undisclosed
or unrecorded accounts, funds or assets– conceal, destroy or improperly altercompany records, accounts and documents– dispose of or otherwise transfer any
Compass assets without authorisation andproper documentation under the Group
Approvals Manual– enter contractual or financial arrangements
without obtaining the required local and/orGroup approvals– provide false, misleading or incomplete
representations in relation to Compass’
financial processes or specific transactions

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIALINTEGRITYCOMMECIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPIT IS CRUCIAL THAT WE
ENSURE THAT PERSONAL DATAIS ALWAYS KEPT SECURE.
Treating personal data with care is very important to ourbusiness. When collecting personal data in our business, wemust strike an appropriate balance between an individual’s
right to privacy and the legitimate business purpose or legal
requirement for using, processing or storing their personal
data. When we work with others who we may share personal
data with, or receive personal data from, we make it clear tothem the importance we place on privacy and the standards werequire to be met.

If you think that the standards in theGroup Data Privacy Policy (internal only)
or applicable country privacy policy havenot been met, become aware of a data
breach or have concerns about sharing or
using personal data, contact your country
Data Protection Champion, Legal orGroup Ethics & Integrity immediately

24

COMPASS GROUP PLC CODE OF BUSINESS CONDUCT

DO

Compass holds personal data about our colleagues, customers,
suppliers, shareholders and other third parties. Personal data
includes any information that identifies an individual or makes
them identifiable. This information can be held in paper files aswell as electronically.

– comply with all applicable data privacy laws
and regulations– ensure when collecting and handlingpersonal data or personal identifiable
information (“personal data”), it is for alegitimate business purpose– ensure personal data is only used for the
purposes for which it was obtained and be
careful not to collect more personal data
than is necessary for the relevant purpose– respect the rights of data subjects and act
in accordance with local law in responding
to requests or notices received, whereapplicable– store personal data securely on Compass’
information technology systems– share personal data (whether internally or
externally) for legitimate business purposes
only, on a need-to-know basis and in asecure manner– ensure that personal data is transferred to athird party via approved transfer
mechanisms. If unsure, seek guidance from
Digital & Technology– ensure that anyone receiving personal data
understands the importance of keeping thedata private and secure, using it only for theagreed purpose– report potential data privacy incidents
immediately to Legal or your country Data
Protection Champion

DON’T

DATA PRIVACY– hold personal data for longer than ispermissible or necessary– use personal data for unauthorised
purposes– transfer data to other countries in an unsafe
or insecure manner or without adequate
protection– provide data to unauthorised persons in or
outside of Compass– assume someone else will, or ignore ourpersonal responsibility to, report or record apotential data privacy incident

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETY

EXTERNAL
ACTIVITY

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPINTRODUCTION

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COMPANY ASSETSSPEAKUPIn many instances, the laws that apply when working with thegovernment may be stricter than those that apply whenworking with private companies. As with everyone we dobusiness with, we work to be a responsible partner to thegovernment and adhere to the highest ethical standards.

IT IS COMPASS POLICY NOT TO MAKE ANY
POLITICAL DONATIONS.

For more information, refer to ourBusiness Integrity Policy or contact Legalor Group Ethics & Integrity

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

As part of doing business, Compass sometimes engages withgovernment bodies, public interest groups, industry
associations and other similar bodies around the world. Whilst
doing this, we must ensure compliance with local laws
governing political activity.

– comply with all applicable laws andregulations– ensure that we are truthful and accurate,
and that Compass’ legitimate interests areprotected– co-operate with any government orauthorities’ investigations and audits– keep the appropriate Line Manager
informed about any planned
communication with designatedgovernmental agencies and seek theirapproval before engaging with such parties– obtain relevant approvals if certain routine
activities unintentionally fall within the wide
definition of matters constituting political
donations and political expenditure under
the UK Companies Act 2006
– seek guidance from Group Company
Secretariat if unsure of what activity could
be defined as a political donation and/or
political expenditure

DON’T

DEALING WITH REGULATORY BODIES AND POLITICAL ACTIVITY– make a donation on behalf of Compass toany political organisation which promotes apolitical party or activities– make political donations or provide
contributions to a political party or
candidate for office– engage in lobbying or have contact withlegislators, political candidates, regulators,
government employees or public interest
groups, unless we are doing so under theguidance of Group Legal, Group
Communications and Group Investor
Relations

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYPERSONAL INTEGRITYCOMMERCIAL INTEGRITY

EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPWE ARE COMMITTED TO SHARING
ACCURATE INFORMATION ABOUTOUR OPERATIONS AND FINANCIALPERFORMANCE WITH OURSTAKEHOLDERS, INCLUDING MEDIA,
PRESS, INVESTORS AND REGULATORS.
We will comply with our market disclosure obligations and areopen and honest in our external communication.

For more information, contact yourCommunications team, Group
Investor Relations or Legal

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

We may sometimes be asked to respond to questions fromexternal individuals or organisations, or receive enquiries fromthe media, press, analysts or the investment community.

– obtain approval from Group
Communications, Group Investor Relationsand Group Legal before providing responses
to media or press for or on behalf ofCompass Group PLC– ensure that advice and approvals, whererequired, are obtained from our Legal andCommunications teams before providing
responses to media or press for or on behalfof a Compass operating entity– obtain authorisation and advice from our
Legal and Communications teams before
making contact with any government,
regulators, legislators or lobby groups on
behalf of a Compass operating entity– check with our Communications and Legalteams on disclosure to the media or press if
unsureDON’T

EXTERNAL COMMUNICATION– make public statements or respond,
formally or informally, to the media, analysts
or investment community unless designatedas a Compass spokesperson and/or
authorised to speak on Compass’ behalf– release any statement, press release orpresentation (oral or written) which may
contain or amount to inside information
without prior approval from Group Company
Secretariat, Group Legal and Group Investor
Relations

INTRODUCTION

THE COMPASS WAYHEALTH AND SAFETYCOMPANYASSETS

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPAt Compass, we operate with high integrity. Our reputation
depends on the integrity of our business dealings and actions.

WE ALL HAVE A RESPONSIBILITY FOR
ENSURING OUR COMPANY ASSETS,
WHETHER PHYSICAL, DIGITAL OR
INTELLECTUAL PROPERTY, ARE ONLYUSED FOR LEGITIMATE BUSINESSPURPOSES, AND THAT WE HANDLE THEM
WITH CARE AND PROTECT THEM FROM
LOSS, DAMAGE, THEFT, FRAUD OR MISUSE.
As a market leader in the food service and support services
sector, we often produce recipes, processes, non-public ideas
and strategies that belong to Compass which we must protect.
We protect our intellectual property (including brands,
trademarks, copyright, patents and trade secrets) and closely
monitor for unauthorised use of our intellectual property byothers.

For more information, refer to theapplicable Group or local Information
Technology Acceptable Usage Policy orcontact Digital & Technology or Legal

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COMPASS GROUP PLC CODE OF BUSINESS CONDUCTDO

Our company assets are the tools, equipment, goods, systems,
information and data we use in our work every day.

– comply with all applicable laws andregulations– use information technology in accordancewith the applicable Group or local
Acceptable Usage Policy– protect Company assets and always guard
them against misuse, loss, fraud or theft
and only use them in a professional andresponsible manner at all times– ensure that Company assets that we use orcome into contact with as part of our work
are not damaged, misused or wasted– protect our intellectual property rights andonly use our intellectual property for
legitimate business purposes, underappropriate protections– stay alert and report to Digital & Technology
unauthorised attempts to access our
systems or devices such as phishing emails
or other cyber threats– seek guidance from Digital & Technology if
unclear or unsure about using or accessing
digital assets or information technology– ensure we report any misuse of company
assets by others to our Line Manager or
submit a report through Speak Up, We’re
Listening

DON’T

COMPANY ASSETS AND BRAND PROTECTION– access, transfer or remove Company assets
without permission or use them forinappropriate purposes– knowingly commit, be a party to or be
involved in any fraudulent activities or theftwhatsoever– agree to share or assign our intellectual
property rights outside Compass without
first consulting with our local Legal teamand seeking approval– use Company assets for personal gain or forreasons unconnected with our role atCompass– misuse our clients’ intellectual property
rights– install or use any unauthorised hardware orsoftware on any Compass information
technology system– intentionally bypass any information
technology or cyber security control

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EXTERNAL ACTIVITY

COMPANY ASSETSSPEAKUPSPEAK UP, WE’RE LISTENING
We take reports and concerns raised through our Speak Up,
We’re Listening programme very seriously and will follow up on
allegations of wrongdoing or unethical behaviour promptly. To
safeguard its integrity, our Speak Up, We’re Listening platform
and helpline is operated by an independent third-party provider
and is available 365 days a year, 7 days a week, 24 hours a day,in all of the countries in which we operate.
For queries about suspected or actual breaches of the Code, tellsomeone you trust in the way you feel most comfortable with,using any of our Speak Up resources:– your Line Manager or more senior manager– your local Human Resources manager or Listen Up Champion– a member of your country, Regional or Group Legal team
– a member of Group Ethics & Integrity– or raise your concern through the Speak Up,
We’re Listening platform

Confidentiality
Compass commits to protect the confidentiality of any person
making a report. When submitting a report, you can choose toremain anonymous. It is important to know that the information
provided and the right to confidentiality or anonymity may besubject to local laws.

Anti-retaliation

For more information, refer to
our Speak and Listen Up Policy
on our website

30

COMPASS GROUP PLC CODE OF BUSINESS CONDUCTIF IN DOUBTSPEAK UP,WE’RE LISTENING.

COMPASS STRICTLY PROHIBITS AND
DOES NOT TOLERATE RETALIATION OR
DETRIMENTAL CONDUCT IN RESPONSE TO
YOU RAISING A CONCERN OR BEING ABLETO RAISE A CONCERN.
Compass commits to protect you and the individuals
conducting, assisting or participating in an investigation against
detrimental conduct or retaliation.