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CODESUPPLIER

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A PARTNERSHIP BASED ON SHARED

VALUES

INTRODUCTION As a world leading food and support services company, we have set the very highest standards for the way we run our business, including the way we work with our suppliers.

Our aim is to establish relationships that are mutually beneficial. We will always treat our suppliers and their subcontractors honestly and fairly. We expect them to match our high standards across the Corporate Responsibility spectrum, including ethical trading practices, food safety, working conditions, health and safety, and environment protection.

This document sets out the way in which we seek to work with our suppliers. It is not a prescribed list of ‘dos’ and ‘don’ts’. That is not the way we do business. We want all our stakeholder relationships to be based on honesty, respect, fairness, a commitment to open dialogue and transparency.

Our aim is to establish relationships that are mutually beneficial.

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COMPASS GROUP AND CORPORATE RESPONSIBILITY

HOW WE WORK Our approach to Corporate Responsibility is at the heart of what we do. It informs how we run every aspect of our business – from strategic planning to day-to-day operations.

It defines our goals in a way that reflects our values, connects our business decisions to ethical, social and environmental concerns, and helps to ensure that we live up to what all of our stakeholders expect of a global organisation.

This commitment to setting the highest standards for responsible business practice is underpinned by a global framework of policies set out in our Vision and Values, our Code of Business Conduct, our Code of Ethics and our Group policies. You can also find out more about how our values determine our actions by visiting our website.

...ensuring we live up to what all of our stakeholders expect...

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BUSINESS ETHICS

HOW WE WORK Covering relations with our employees, customers, investors, governments and the wider community as well as our suppliers, our Code of Business Conduct establishes clearly our commitment to full compliance with all local laws and the stand we take against all forms of bribery and corruption.

More specifically, it states that no employee may offer or receive – or influence others to offer or receive – any money or material gift that could be construed as a bribe or an attempt to influence; that we will constantly strive to ensure we are not exploited directly or indirectly by requests to make facilitation payments; and that we will not work with companies that infringe the law or endanger Compass Group’s reputation.

To help ensure that any abuses of our Codes of Business Conduct and Ethics are brought to light, we operate a Speak Up programme. This strictly confidential Group-wide, telephone helpline and website service enables any employee to raise any concerns he or she may have about improper, unsafe, unethical or illegal behaviours or activities. Run by an entirely independent specialist provider, the service is accessible 7 days a week, 24 hours a day.

...we will not work with companies that infringe the law or endanger Compass Group’s reputation...

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HUMAN RIGHTS

HOW WE WORK Compass Group, a signatory to the United Nations Global Compact since 2004, fully endorses the view that human rights are basic rights to which everyone is entitled. However, we recognise that it is not enough to simply make declarations.

In addition to setting up and continually developing our Speak Up programme – an effective guarantee for every one of our employees that their voice will be heard if they are witness to, or subjected to, any abuse of their human rights – we are also taking positive measures to ensure that we are contributing fully to realising the objectives of the Modern Slavery Act (2015). We have, for example, fully embraced the principles of the Ethical Trading Initiative Base Code as a framework for safeguarding against any instances of discrimination or exploitation.

Upholding human rights is fundamental to our concept of Corporate Responsibility and a commitment that we expect all of our suppliers to share.

Compass Group Human Rights Policy Statement

Human rights are basic rights to which everyone is entitled.

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HEALTH, SAFETY AND

ENVIRONMENT

HOW WE WORK Health and Safety and Food Safety

We believe that everyone working for, and with, Compass has a moral obligation to ensure a safe, injury-free and healthy workplace wherever that may be. Our goal is a safety culture which ensures that people instinctively take individual and collective responsibility for preventing all accidents, including trips and falls.

Serving food that is always safe to eat and prepared using high quality, responsibly sourced and traceable ingredients has to be one of our primary concerns. To that end, we insist, as an absolute minimum, on full compliance with all relevant legislation and approved codes of practice across the supply chain.

Compass Group Food Safety Policy Statement

Compass Group Workplace Health & Safety Policy Statement

Compass Group Supply Chain Integrity Policy Statement

Safety First in everything we do.

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HEALTH, SAFETY AND

ENVIRONMENT

HOW WE WORK Environment

Compass Group recognises that its global business operations have an impact on the environment but we are pledged to continually improve our environmental performance, particularly in relation to energy use and food waste. We also recognise that we have a responsibility for the indirect environmental impacts generated across our entire supply chain – which is why we expect our suppliers and contractors to adhere to the same high standards that we impose on ourselves.

Compass Group Environmental Policy Statement

We are committed to continually improve our environmental performance.

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A CLOSER LOOK AT OUR

SUPPLY CHAIN

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Why it matters to... THE WORLD

Bribery, corruption, exploitation and all other forms of unethical business activity are not victimless practices. Innocent individuals suffer. Not to mention the seriously detrimental and distorting effect that business behaviour of this kind has on legitimate trade across the world.

Why it matters to... COMPASS

Increasingly, our clients and consumers are seeking assurances that the products they consume are sourced ethically and sustainably. They want to know that they are not indirectly supporting unacceptable practices.

By extension, we are also committed to ensuring that all our dealings with suppliers – from the point of search and selection through to supply and payment – are conducted in accordance with our guiding principles of responsible trading.

ETHICALTRADE

A CLOSER LOOK

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Why it matters to... THE WORLD

The world’s livestock herds and flocks are estimated to include 19 billion chickens, 1 billion pigs and 1.5 billion cows at any one time. For many, their welfare is a fundamental moral issue; for others, it is a matter of food safety and human well-being. On either count, animal welfare is an issue of global concern.

Why it matters to... COMPASS

Given that concern, animal welfare has to be a matter of significant concern for Compass. Serving more than five billion meals a year, we recognise our responsibility to take a leadership role on animal welfare both within our industry and across our supply chains. We work closely with animal welfare organisations, suppliers and clients around the world to promote the use of farm assurance schemes that achieve best practices in animal welfare. We also endorse the Five Freedoms proposed by the Farm Animal Welfare Council (FAWC):

1. Freedom from hunger or thirst2. Freedom from discomfort3. Freedom from pain, injury or disease4. Freedom to express (most) normal behaviour5. Freedom from fear and distress

FARM ANIMAL WELFARE

A CLOSER LOOK

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Why it matters to... THE WORLD

Beef is raised in many of the most sensitive and important ecosystems around the world, including North America’s great plains, the Brazilian Amazon, the savannahs of Southern Africa and the Great Barrier Reef watershed of Australia. With the global population expected to exceed nine billion by 2050 and income levels rising, demand for beef is increasing and will only grow. Yet beef production requires a lot of land, water and energy, and generates considerable waste. It is thus essential to improve its sustainability globally.

Why it matters to... COMPASS

In line with our Corporate Responsibility commitments, making beef production more sustainable is an important issue for us. There are, in fact, many ways in which this can be achieved. Grazing maintains the health of grasslands, improves soil quality with manure, and preserves open space and wildlife habitat. Additionally, carbon is sequestered in the grasses and soils of grazing lands. Beef production also provides social benefits by sustaining livelihoods and community vibrancy in rural areas where grasslands dominate.

BEEFA CLOSER LOOK

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Why it matters to... THE WORLD

As the largest traded food commodity in the world, seafood provides sustenance to billions of people worldwide. Approximately three billion people rely on both wild-caught and farmed seafood as their primary source of protein. However, the United Nations Food and Agricultural Organization estimates that eighty-five percent of marine fish stocks are either fully exploited or overfished. Similarly, many fisheries throughout the world throw away more fish than they keep, a practice which is harmful to many species. Moreover, pollution from poorly managed and unsustainable seafood farms has caused the deterioration of coastal habitats, lakes and rivers.

Why it matters to... COMPASS

To ensure that our use of fish and seafood is as sustainable as possible, we only buy fish that comes from well managed marine sources and we do not use any fish on the Marine Conservation Society’s (MCS) Fish to Avoid List. Whether they are supplying farmed fish, wild sea fish or shell fish, we expect our suppliers to be able to demonstrate – through Total Allowable Catch (TAC) data, certification scheme certificates or appropriate scheme membership – that it comes from a sustainable source.

FISH AND SEAFOOD

A CLOSER LOOK

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Why it matters to... THE WORLD

Palm oil is a highly versatile raw material. It has excellent cooking properties and acts as a natural preservative which explains why it is used in many of the products on supermarket shelves. It is also used as a fuel for cars and power plants. Very high-yielding, it needs less than half the land to produce the same amount of oil as other vegetable oil crops.

However, its cultivation has long been associated with deforestation and associated climate change, biodiversity loss, soil erosion and water pollution. In addition, while its production has undoubtedly brought a measure of prosperity to some local communities, there have been persistent allegations of human rights abuses in other parts of the world.

Why it matters to... COMPASS

We understand how important palm oil is as an ingredient to many of our suppliers. At the same time, in order to meet our own social and environmental responsibilities and to be able to assure our clients and consumers, we have to be certain that the palm oil used in our products has been sustainably sourced. That is why we actively support the work of the Roundtable on Sustainable Palm Oil (RSPO) and why we encourage our key suppliers to do the same.

PALM OILA CLOSER LOOK

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Why it matters to... THE WORLD

Soy is a globally traded commodity produced in both temperate and tropical regions and serves as a key source of protein and vegetable oils. Global soybean production today is some 15 times the volume produced in the 1950s. Not only are soybeans made into food products like tofu, soy sauce, and meat substitutes, they are also consumed in the form of soybean oil and soybean meal which is also widely used as animal feed. In addition, soy is increasingly used for biodiesel production.

However, many are concerned that the soybean industry is causing widespread deforestation and displacement of small farmers and indigenous peoples around the globe.

Why it matters to... COMPASS

It is of great importance to us to ensure that we are not contributing to the negative impact that the production of soy can have on the environment and local communities. The majority of soy used in our supply chains is in animal feed used to produce meat, fish and dairy products and we are currently working with an external partner to better understand the soy used in our US and UK supply chains, which accounts for approximately 60% of our global business. We are a member of the Round Table for Responsible Soy (RTRS), a multi-stakeholder initiative that has developed principles and criteria for responsible soy production and we will continue to encourage our key suppliers of animal products to source soy responsibly and, where possible, investigate the feasibility of using alternatives to soy.

SOYA CLOSER LOOK

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Why it matters to... THE WORLD

For many years there has been growing concern about the issues arising from the illegal or unsustainable sourcing of timber products. The unmanaged felling of forests without replacement can cause permanent damage to local ecosystems and a number of already endangered tree species are at risk of being driven to extinction by unsustainable demand for their use in consumer products.

Moreover, unmanaged forestry has resulted in the displacement of many indigenous peoples around the world and affected many more through the loss of livelihoods whilst illegal logging has been linked to poverty and corruption. Unsustainable forestry has also been shown to contribute to climate change and it has been estimated that deforestation globally is responsible for up to 20% of GHG emissions.

Why it matters to... COMPASS

Compass Group relies on the consumption of a number of forest commodities to maintain its worldwide operations. In line with our Corporate Responsibility commitments, we need to ensure that all of our timber and wood-based products are derived from well-managed and sustainable sources. However, determining traceability can be complex with multiple supply chains spanning several countries.

In response to this problem, we are working to ensure that all the forestry products we buy are third party certified by organisations such as the Forest Stewardship Council (FSC).

TIMBER AND WOOD PRODUCTS

A CLOSER LOOK

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WHAT IT MEANS

FOR YOU

The purpose of this document is to give an overview of what we need from you in general terms in order to maintain the kind of mutually beneficial partnership that we both want. Having said that, there are expectations that we have of all our suppliers and their subcontractors.

Read the relevant Compass codes and policiesYou will have noticed that throughout this document we have referred to a number of our codes and policies. Taking the time to read these will give you a more detailed insight into how our approach to Corporate Responsibility affects all of our business activities as well as our relationships with all of our suppliers.

Comply with our supplier audit requestsTo live up to our own standards, we have to take great care when appointing new suppliers or renewing contracts with our existing suppliers. For that reason, we may ask you to complete a detailed Supplier Evaluation Questionnaire. Depending on the nature of your business, this could cover a number of different areas, including your environmental policies and their implementation. Your willingness to engage in this process will obviously have a significant impact on our decision-making process.

Finally, as a truly global organisation, we understand that we live in a complex world; that events can sometimes happen beyond our and your control. For that reason, our focus is always on working with our suppliers to achieve a process of continual improvement rather than on seeking to impose sanctions when something unavoidable happens.

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CODESUPPLIER

Group HSEQCompass Group PLCCompass House | Guildford Street | Chertsey | Surrey KT16 9BQ

Tel: +44 1932 573 000global.hse@compass-group.comwww.compass-group.com

V2: May 2018