Code of conduct_feb11v1

Code of Business Conduct
Compass Group PLC
February 2011

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Page
CONTENTS
Introduction
Message from Richard Cousins 3
Code of Business Conduct 4
Getting Help and Advice 5
Speak Up 6
Visions and Values 7
The Compass Way
Food Safety 8
Responsible Supply Chain 9
Personal Integrity
Conflicts of Interest 10-11
Insider Trading 11
Gifts and Hospitality 12-14
Commercial Integrity
Competition and Anti-Trust 15-16
Money Laundering 16
Bribery and Corruption 17-18
New Territories, New Sectors, Agents and Consultants 18
Reporting and Accounting 19
Data Privacy 20
Employment
Health and Safety 21-22
Fair Treatment and Equal Opportunities 23
Working Without Harassment/Bullying 24
Company Assets
Brand Protection 25
Confidentiality 26
Physical Assets 26
Information Security 27
External Activity
Dealing with Government and Public Regulatory Bodies 28
Community and Charitable Activity 29
Political Activity 30
External Communications 31
Environment 32
Reference
Policies and Further Information 33
Contacts 34
V1 February 2011

INTRODUCTION
Message from Richard Cousins
As a world leading food and support services company, we have set the very
highest standards for the quality of service we provide and the way we run our
business. Working within Compass Group, whether for Eurest, ESS,
Restaurant Associates, Medirest, Morrison, GRSA, Chartwells, Sofra Yemek
or any other member of Compass Group PLC, your actions can affect how we
are viewed. Our success and future depends on each of us acting
professionally, responsibly and in accordance with the standards set out in the
Code of Business Conduct.
The Code of Business Conduct sets out our commitment on how to do business in a fair way: treating everyone –
customers, colleagues, investors, suppliers and sub-contractors, as well as the wider community – with honesty,
integrity and respect.
Every individual in Compass Group shares the responsibility to work to the standards set out in the Code of
Business Conduct and to conduct our business in a professional, safe, ethical and responsible manner. This is
without exception or compromise. The Code of Business Conduct brings together our policies on compliance and
ethical issues and is to be followed by all employees across the Group. Please make sure you familiarise yourself
with the Code of Business Conduct and the policies referred to in it.
The Code of Business Conduct is based on our beliefs and values and demonstrates our commitment to living those
values in the way we conduct business. The Code of Business Conduct also refers to the Compass Speak Up
programme which allows employees in the business to speak to someone independent and in confidence if they are
unsure of what do in a particular circumstance or are concerned that the Code of Business Conduct is being broken.
We all have a responsibility to “speak up”.
The Code of Business Conduct is fully supported by the Compass Group PLC Board of Directors and the senior
leadership team.
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Richard Cousins
Group Chief Executive
February 2011
Q: Why do we need a Code of Business
Conduct?
A: The Code of Business Conduct is a
demonstration of our commitment to obtaining
and maintaining the highest level of ethical
standards wherever we operate. The Code of
Business Conduct sets out what Compass
expects of its employees, business partners
and suppliers and provides guidance on how
Compass employees should live the Compass
values in their everyday work around the world.
Q: How does the Code of Business Conduct
apply in different countries?
A: As a global business operating in many
countries across the world, Compass
recognises that the laws and regulations differ
from country to country, or even state to state.
Each of us must take responsibility for
ensuring compliance with the laws of the
country in which we work. If there is any
conflict between the guiding principles set out
in the Code of Business Conduct and local
laws in the country in which you work, you
should follow and apply whichever sets the
higher standard of behaviour.

Code of Business Conduct
The Code of Business Conduct applies to everyone working for Compass, without
exception. This includes temporary and contract staff and is regardless of location,
role or level of seniority. We each have a responsibility to make ourselves aware of
the contents of the Code of Business Conduct and if there is anything you are not
sure about, you should speak to your Line Manager. Each of us should make sure
that we fully understand what is expected from us in our roles and how the policies
contained in the Code of Business Conduct apply to us.
As well as Compass employees, we should not engage any contractor, agent, consultant, supplier, client, customer,
business partner or any other third party whose business practices conflict with the Code of Business Conduct.
If you are engaging any third party to act on behalf of Compass, it is your responsibility to ensure that they are made
aware of the Code of Business Conduct and that they agree to act in accordance with it. Where possible, you should
seek a contractual obligation from them to comply with the Code of Business Conduct and you should actively
manage the third party to ensure that they continue to act in accordance with it. Any breaches of the Code of
Business Conduct by third parties or examples of behaviour inconsistent with the Compass Values (as set out later)
should be reported to your Line Manager. You should seek to eradicate any such behaviour and where necessary,
consider terminating the relationship.
Please also remember that the appointment of professional advisors or consultants must first be approved in
accordance with the Group Approvals Manual. No consultants or professional advisors may be appointed without
this prior approval.
In countries where we operate in a joint venture, we will strive to apply the Code of Business Conduct as though we
wholly operate the business and will proactively seek to influence our business partners to adopt similar principles.
All employees are required to follow the Code of Business Conduct and the policies contained in it (including new
employees joining the Compass Group through acquisitions or contract wins). A failure to follow the Code of
Business Conduct may result in disciplinary action up to, and including, dismissal.
If you are responsible for supervising
or managing colleagues within
Compass, you have additional
responsibilities to ensure that:
 You are a good role model to your
direct reports and by example,
demonst rate good ethical
behaviour;
 All your direct reports are aware of
the Code of Business Conduct and
have the opportunity to discuss its
application to their role – and of
course, any concerns that they
may have – you might consider
making this a part of the annual
appraisal; and
 The Code of Business Conduct is
actually being followed by those
who report in to you – consider this
when setting objectives and work
projects and act promptly if you
become aware of any breaches of
the Code of Business Conduct by
immediately escalating the matter
to your own Line Manager or local
legal department.
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INTRODUCTION

INTRODUCTION
Getting Help and Advice
It may feel easier to remain silent or ignore unethical behaviour but our commitment to integrity means that none of
us should ignore a legal or ethical issue that should be addressed.
Each of us has a responsibility to report any potential or actual breaches of the Code of Business Conduct or any
behaviour which is contrary to Compass Values and business principles. This duty applies whether it is you directly
or if you become aware of an issue involving a colleague or a third party connected with Compass.
Where possible, you should firstly consider talking to your Line Manager about any legal or business conduct issue.
If you are uncomfortable talking to your Line Manager or it is not appropriate in the circumstances, you can also get
advice and guidance from:
 your local legal team;
 Group Legal;
 your HR team;
 Group Internal Audit; or
 your local senior management team.
The Reference section which you will find on page 33 at the end of the Code of Business Conduct contains some
helpful contact information.
You can also make use of our Speak Up facility, details of which can be found on page 6.
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Q: Does the Code of Business Conduct
contain everything I need to know?
A: You will find examples of situations that may
arise during the course of your employment
throughout the Code of Business Conduct,
together with guidance as to how Compass
expects you to behave in those situations.
However, it is impossible to cover every
possible scenario that may arise and as a
world leading professional organisation,
Compass expects each and every one of its
employees to take personal responsibility for
acting in accordance with the principles
contained in the Code of Business Conduct.
The “Questions & Answers” are intended to
answer both specific questions that may arise
and also illustrate more generally how we
expect you to behave.

INTRODUCTION
Speak Up
‘Speak Up’ is a Group-wide facility in Compass for our people to confidentially raise
their concerns over actions and behaviour that they feel may be improper, unsafe,
unethical or even illegal; issues that they feel they cannot raise with their Line
Manager or through normal procedures. Employees can do this via a confidential
telephone helpline and web-site, which is run by an independent specialist provider
and is available 7 days a week, 24 hours a day.
Our reputation is based on the standards we set for the quality of services we provide; our operating controls and
practices; and our ethics and integrity. If these standards are compromised, we undermine our reputation and place
at risk the security and future success of the business. We cannot allow this to happen. We all share the
responsibility for conducting our business in a professional, safe, ethical and legal manner.
Key to achieving this is to have a culture of open, honest communication, where our people feel that they are able to
raise with their Line Managers or supervisors activities or behaviour that they feel breach these standards, and
potentially put themselves, their colleagues, our clients and customers, our business and our reputation at risk.
Whilst we believe we have such a culture, we want to ensure that every one of our people feels empowered to
“speak up” on these issues. However, it’s not always that simple. For whatever reason, people sometimes feel that
they cannot “speak up”.
The Speak Up programme provides a confidential way for our people to raise issues where they feel their safety,
that of their colleagues or of our clients, customers and business partners, our standards or our reputation are being
placed at risk.
All issues are handled by independent specialists, who are not employed by Compass Group. Contact with Speak
Up is completely confidential and there is no requirement for you to leave your details, unless you are comfortable
doing so, although it would be more helpful to ensure a more complete investigation if you gave your personal
details. Each report is forwarded to a specially trained 'case manager' who conducts a confidential investigation into
the reported issue.
In many countries the Speak Up helpline has been set-up in more than one language, e.g. Kazakhstan, where
operators are available who speak Kazakh, Russian and English.
If you would like feedback or an update, you can re-contact Speak Up using a unique identification number around
14 days after your original report was made. Compass will not tolerate any reprisal for reporting a problem, raising a
concern or assisting in an investigation. Anyone found to be involved in retaliation against any individual who has
raised concerns in good faith will be subject to disciplinary action.
A link to further information on the
Speak Up programme can be found
in the Reference section of the Code
of Business Conduct on page 32.
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Q. My manager has asked me to do something
that I don’t think is right. I tried to discuss it
with him but he just told me to get on with
it. I’m worried that my manager will make
things very difficult for me or I will lose my
job if I call Speak Up about this.
A: We would always encourage you to talk to
someone if you become aware of an issue that
is a concern to you. If you are unable to talk to
your Line Manager about this or any other
senior colleagues, we recommend you call
Speak Up. Any issues you report or raise will
be investigated and we will not tolerate any
retaliation against you for reporting the matter.
You must do the right thing and report the
matter.

Our Visions and Values capture in words the spirit of Compass and what
we stand for. They guide the decisions, actions and behaviours of our
people; are evidenced in our customers' experience of the service we
deliver every day globally; and drive our performance and growth.
Our Vision – sets out what we want to be
To be a world-class provider of contract foodservice and support services, renowned for our great people, our great
service, and our great results.
Our Mission – sets out how we are going to achieve this
Everyone in Compass is committed to consistently delivering superior service in the most efficient way, for the
shared benefit of our customers, shareholders and employees.
Our Guiding Principles – these set out what guides our decision making
Safety, Health and Environment First – never to compromise on the health and safety of our customers and our
people, and to manage responsibly the impact that our business has on the environment;
Delivering for Clients and Consumers – to earn the continued loyalty of our customers by consistently
demonstrating why we are the first choice for quality, service, value and innovation;
Developing our People and Valuing Diversity – to recognise the diversity and contribution of our people. We
create a work environment that is challenging and provides the opportunities and support for everyone to develop,
learn and succeed;
Profitable Growth – to deliver shareholder value through disciplined, sustainable growth, underpinned by strong
governance, that contributes to and leverages the benefits of our global scale; and
Constant Focus on Performance and Efficiency – to deliver the highest quality and performance, whilst
relentlessly driving to be the lowest cost, most efficient provider.
Our Values – these set out what we collectively believe in and guide our behaviours.
Openness, Trust and Integrity – we set the highest ethical and professional standards at all times. We want all our
relationships to be based on honesty, respect, fairness and a commitment to open dialogue and transparency;
Passion for Quality – we are passionate about delivering superior food and service and take pride in achieving this.
We look to replicate success, learn from mistakes and develop the ideas, innovation and practices that will help us
improve and lead our market;
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 other and 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 wellbeing of our customers, the communities we work in and the
world we live in; and
Can-do – we take a positive and commercially aware "can-do" approach to the opportunities and challenges we
face.
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VISION & VALUES
If you are faced with a situation where
you are unsure of the correct course
of action to take, you may find it
helpful to ask yourself the following
questions:
1. Is the action legal?
2. Is it in line with the Compass
Values?
3. Does it conflict with our Guiding
Principles?
4. What would others think about
this? and
5. Would you be comfortable if it was
reported in a newspaper?
If you still have concerns after
considering these points, make sure
you seek guidance from your Line
Manager, your local HR team or your
local Legal team.
Don’t forget, you can always discuss
any concerns or issues that you may
have by contacting Speak Up.

THE COMPASS WAY
Compass prides itself on its great food and great service. We work with some of the
most renowned chefs in the world and employ those we believe to be the best in our
industry.
The menus and dishes our chefs create provide a choice of high quality, nutritious and
well balanced food. It is our innovation that makes us a market leader. We relentlessly
pursue delivering the highest quality in the most efficient way.
Food Safety
Our primary concern is that the food we serve is prepared to the very highest standards using quality products and
ingredients. As a very minimum we will comply with all relevant food safety legislation and approved codes of
practice.
To ensure best practice we have developed a common minimum operating standard and set of behaviours which
must be practiced at every location we operate. These are based on sound science, regulatory requirements, and
industry best practice.
We regularly measure compliance against these standards and implement performance objectives to assure our
clients and customers that we are providing food which is safe to eat whilst meeting their quality expectations.
All employees who work with food are expected to ensure that:
 Food is always prepared under sanitary conditions that do not expose it to the risk of contamination;
 They are provided with the information, training and tools necessary to do their job in a hygienic and compliant
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manner; and
 They comply with all company food safety policies and procedures.
Management assumes the role of supervision of our employees for compliance and conformance with these
standards.
A link to our Food Safety Policy
Statement can be found in the
Reference section of the Code of
Business Conduct.
Q: I have noticed that one of my colleagues
sometimes forgets to wash her hands
before preparing food. Should I say
something to her?
A: Your hands can easily spread bacteria around
the kitchen and onto food so it is really
important that you always wash your hands
thoroughly before and after any food
preparation, as well as after you have been to
the bathroom or touched waste bins/trash
cans. Please do remind your colleague of this
and if appropriate, raise it with your Line
Manager.

THE COMPASS WAY
Responsible Supply Chain
As a Group, Compass purchases goods and services from a wide variety of suppliers from large international
organisations to specialist local suppliers, all over the world.
Where possible, we source food and ingredients from growers and producers local to our units, purchase from
organic producers and participate in fair trade initiatives. We place great emphasis on sustainable sourcing.
We recognise that there will be suppliers in some countries that will find it harder to meet the exacting standards
expected of large international corporations. In those cases, we will expect such suppliers to meet the requirements
of the Compass Small/Medium Enterprise Audit and to demonstrate continuous improvement.
As a minimum, our procurement activity will comply with relevant Food Safety and Health and Safety standards,
Codes of Practice, Company regulations, laws and standards in the countries in which we operate and will reflect
our ongoing commitment to sustainable food procurement and corporate responsibility (“CR”).
Compass constantly strives to find the right balance between building long-term supply relationships based on the
compatibility of values and behaviour, as well as quality and price.
Suppliers are selected and retained through a non-discriminatory bidding and tendering process. Our positive
selection of suppliers includes, where practicable, a review of the supplier’s policy and activities in relation to good
CR practices. We expect our larger suppliers to meet a robust set of CR criteria and we encourage and assist the
adoption of best practice amongst all suppliers and expect all of our suppliers to abide by the law and to recognise
our Code of Ethics.
If your role involves selecting or working with suppliers you should ensure that, from the point of search and
selection, through to supply and payment, your relationship is conducted in accordance with the guiding principles of
responsible and ethical trading.
As a minimum we will act within the Base Code of the Ethical Trading Initiative which is an internationally recognised
code of labour practice, the key elements of which are:
 Freedom of association and the right to collective bargaining is respected;
 Working conditions are safe and hygienic;
 Child labour shall not be used;
 Living wages are paid;
 Working hours are not excessive;
 No discrimination is practised;
 Regular employment is provided; and
 No harsh or inhumane treatment is allowed.
You can find out more information about our work with suppliers by reading our Purchasing and Supply Policy
Statement. A link to this is contained in the Reference section of the Code of Business Conduct.
If you have any concerns about the
conduct of our suppliers or any
Compass employee relationships with
suppliers, please speak to either your
Line Manager or your local
procurement manager.
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Q: One of the suppliers who is tendering for
business with Compass has indicated that
if we tell him what price the other potential
suppliers are offering, he will guarantee to
offer us greater savings. This could be
great news from a financial perspective for
Compass but I feel a bit uneasy about it.
What should I do?
A: You are right to feel uneasy about this. If
something doesn’t feel right, it probably isn’t.
Whilst it is important to look after the best
interests of Compass at all times, you should
never share supplier information with other
suppliers. Not only is this a breach of
confidentiality but you may also be breaking
the law. You should explain to the Supplier
that what he has suggested is unethical and is
not allowed by Compass. You should report
the matter to your Line Manager and you may
wish to consider whether this supplier is one
that you wish to continue doing business with.

PERSONAL INTEGRITY
Conflicts of Interest
Employees must take care to ensure that no conflict of interest – actual or perceived
– arises between their duty as a Compass employee, and any interests outside of
work.
Conflicts of interest can arise in many ways:
Other work interests and affiliations: undertaking employment for other
companies whilst employed by Compass or being affiliated to other organisations can create conflicts of interest.
For example:
 having a financial interest in another company or organisation;
 holding a Director or consultant position;
 performing services outside of your Compass role; or
 having a second job.
If any of the above relate to a company or organisation that may be considered a competitor of Compass or a client,
contractor or supplier to Compass, a conflict of interest may arise.
Some arrangements of this kind are never permissible – you should not work or provide services for any company or
organisation that you deal with in your role at Compass. If you are considering taking on additional work outside of
Compass that may result in a perceived or actual conflict of interest, you should disclose this to your Line Manager
and seek their written approval to continue with your plans.
Working with close relatives: if you become aware that a close relative works for or provides services to a
competitor, client, contractor or supplier, you should discuss the matter with your Line Manager.
As a general rule, a relative should not have any business dealings with you and where at all possible, with anyone
in your business unit or anyone who may report in to you. For the purposes of the Code of Business Conduct, we
consider that a “close relative” would include a spouse, partner, parent, step-parent, child, step-child, sibling, step-sibling,
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nephew, niece, aunt, uncle, grandparent, grandchild or in-laws.
Board of Directors
We recognise that as a professional organisation, our employees may sometimes be asked or invited to serve on
the board of directors of another organisation, and this can, in some circumstances, raise a conflict of interest or a
legal issue. Before you accept a position as a board member for any organisation (including not-for-profits), you
should first get written approval from your country Managing Director.
You can get further advice and sup-port
regarding conflicts of interest
from your Line Manager, your local
legal team or your local HR team.
Q: We are looking to recruit some additional
catering staff in the unit where I work. My
daughter is looking for some part time work
before she returns to university and I am
wondering if I can put her name forward for
a role?
A: If you think that your daughter is suitable for
the vacancy and has the right personal
attributes and experience, then we would
encourage you to speak to your Line Manager
and recommend her for consideration. You
must make it clear that you are related and
should have no involvement in the recruitment
process and the vacancy should be for one
that you do not directly supervise or work
closely with.

PERSONAL INTEGRITY
Conflicts of Interest (cont’d)
Investments
Conflicts of interest may occur if investments are made in competitors, suppliers or customers. Any “substantial
interest” in a competitor, supplier or customer requires the prior written approval of your country Managing Director.
For the purposes of the Code of Business Conduct, a “substantial interest” means any financial interest that might
actually or be perceived to influence your judgement. Investments in public companies which are quoted on a
recognised stock exchange (such as the CAC 40, NYSE or the London Stock Exchange), where your ownership is
less than 1% of that company, are acceptable.
Many actual or potential conflicts of interest can be resolved in a way that is acceptable for both Compass and the
individual. The important thing is to highlight the potential conflict so that an appropriate course of action can be
agreed.
If you are concerned that you (or a colleague) may have a conflict of interest, you must disclose this to your Line
Manager. Failure to disclose a conflict of interest may lead to disciplinary action.
Insider Trading
Trading using “inside information” is a criminal offence in the UK, US and many other countries. Inside information is
material information about a company which is known to directors and employees of the company but has not been
released to the public. It may also relate to another publicly trading company. Sharing inside information or using it
to buy or sell shares is not allowed.
You should not buy or sell Compass shares (or those of any other listed company) if you are in possession of inside
information. You should not ask other people to trade on your behalf or confide in others with the inside information
that you have.
No inside information should be disclosed by any business without the prior written approval of either the Group
Chief Executive, Group Investor Relations, Group Media Relations or the General Counsel & Company Secretary
who will:
 Ensure that the inside information is made available as required by law;
 Release the inside information via the London Stock Exchange (or such other permitted mechanism); and
 Make announcements available on the Compass Group PLC website.
Full contact details for these departments can be found in the Reference section of the Code of Business Conduct.
Material information is information
which would be likely to affect the
company’s share price, once it is
known to the public. For example,
information about a management
restructure, new product information,
significant new contracts, major
litigation or earnings statements or
forecasts.
You can get further advice and
support regarding conflicts of interest
and insider trading from your Line
Manager, your local legal team or
your local HR team.
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Q: We have been working on agreeing a joint
venture agreement with a new business
partner which, if successful, could really
grow the business of both companies. I am
aware that my sister and brother-in-law
have some shares in the other company
that they have been thinking of selling. I
would like to ensure that they receive the
best price for their investment and tell them
to hang on to the shares until our business
relationship is announced. Will I get into
trouble for doing this?
A: Yes. The information you have about the new
joint venture relationship is confidential and
should not be shared. It is likely to be
considered material information as investors
(such as your family) would probably consider
the information when making a decision about
their shares. You must not disclose the
information.

PERSONAL INTEGRITY
Gifts and Hospitality
We appreciate that giving and receiving gifts or hospitality can help build goodwill in
business relationships but they are only appropriate in limited circumstances.
In no circumstances should any employee offer, give or accept any gift or hospitality,
regardless of value, which might be construed as influencing a business decision.
Consider the following points when you are faced with an opportunity to give or receive gifts or hospitality:
 What is your intention when offering a gift or hospitality or what do you think is the intention of the business
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partner when offering the same to you?
 Is the intention to build a business relationship or to influence a business decision such as the award of a
tendered contract?
 Is the nature of the gift or hospitality modest or could it make you (as the recipient) feel under an obligation to
give something back?
 Have you checked to see if the gift/hospitality is legal in the country of both the recipient and the offeror? Be
particularly careful when considering gifts or hospitality for government officials as some countries do not allow
this.
 Have you checked if the recipient of the gift or hospitality is allowed under their gifts policy to receive this?
 Are you happy to justify giving or receiving the gift or hospitality? If it doesn’t feel right, it probably isn’t.
Does it matter what kind of gift or hospitality I offer?
There are some kinds of gifts or hospitality which should never be considered as acceptable. You should not give,
offer, receive or approve any:
 Gifts or hospitality involving third parties involved in any competitive bid or tender process that you are – or may
be considered to be – involved in;
 Gifts or hospitality that would be illegal under local laws such as offering a gift to a government official which may
be seen as a bribe under local law – please ensure you are familiar with your local legal obligations;
 Payments of cash (or cash equivalents) or paying someone else’s personal bills or expenses;
 Any hospitality that might be in breach of this Code of Business Conduct or that may be considered indecent or
inappropriate as part of a business relationship or which may have a negative affect on Compass’ reputation;
and
 Gifts or hospitality that you are not prepared to report or seek approval for internally irrespective of whether you
use personal or company hospitality.
Q: I have been in discussions for many
months with a local government body
about outsourcing support services. I have
now been invited to the wedding of the
daughter of a local government official. It
is expected in my culture that guests will
give cash gifts at the wedding. Is this
acceptable?
A: We appreciate that cultural differences may
sometimes present us with difficult situations
and whilst we wish to always remain sensitive
to this, offering a cash gift is strictly prohibited,
regardless of the circumstances. It may be
appropriate to offer a non-cash gift, but you
must discuss this first with your Line Manager
and get his/her prior approval before giving
out any gift.

Gifts and Hospitality (cont’d)
You must always seek prior approval from your Line Manager before offering or accepting any gift or hospitality.
For Top 10 Countries
You must always seek approval from your Managing Director (or other appropriate officer designated by your
Managing Director) before offering or accepting any gift or unbudgeted hospitality* which may exceed, for each
recipient, the following limits in any 12 month period commencing 1 October each year:
 Hospitality (including meals) that exceeds the lower of (a) £3,000 or (b) the lower local limit set by your country
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Managing Director;
 Gifts valued at more than £100 (or any lower local limit); or
 Travel or overnight accommodation provided or offered by way of hospitality.
In addition, prior approval must be sought from your Group Managing Director for a) any hospitality valued at more
than £5,000 (for up to 5 people); b) any hospitality valued at more than £7,500 (for between 6 - 10 people) or c) gifts
valued at more than £500. AIC approval must always be sought for gifts valued at more than £2,000 and for
hospitality valued at more than £75,000.
For All Countries outside of Top 10
You must always seek approval from your Managing Director (or other appropriate officer designated by your
Managing Director) before offering or accepting any gift or unbudgeted hospitality* which may exceed, for each
recipient, the following limits in any 12 month period commencing 1 October each year:
 Hospitality (including meals) that exceeds the lower of (a) £1,500 or (b) the lower local limit set by your country
Managing Director;
 Gifts valued at more than £100 (or any lower local limit); or
 Travel or overnight accommodation provided or offered by way of hospitality.
In addition, prior approval must be sought from your Group Managing Director for a) any hospitality valued at more
than £2,500 (for up to 5 people); b) any hospitality valued at more than £5,000 (for between 6 - 10 people) or c) gifts
valued at more than £250. AIC approval must always be sought for gifts valued at more than £1,000 and for
hospitality valued at more than £75,000.
Top Ten Countries: US, Canada,
Brazil, Germany, Spain, France, UK,
Italy, Australia and Japan.
* Hospitality (whether provided at a
Group operated venue or purchased
from a third party) that has already
been included in a cost-centre
budget, which has been approved as
part of the setting of that financial
year’s budget by the relevant
country’s GMD and which is subject
to periodic reviews during the
financial year, is not subject to the
financial thresholds set out above and
is deemed to have already received
an appropriate level of scrutiny and
authorization. The requirements of
this policy as to the time at which
hospitality is offered and so on (e.g.
not during a tender) apply.
PERSONAL INTEGRITY

Gifts and Hospitality (cont’d)
Please note that these values are Group standards which are set out in the Group Approvals Manual, which may be
subject to change from time to time. The local gifts and hospitality policy in the country in which you work may set
more stringent thresholds with which you must comply. It is your responsibility to familiarise yourself both with the
thresholds that apply in your local country and the thresholds set out in the Group Approvals Manual.
Accepting Gifts
We appreciate that in some countries and cultures, it may be considered an insult to decline a gift that is offered to
you but would otherwise be in breach of the Code of Business Conduct. In such circumstances, you may accept the
gift but you must immediately report it to your Line Manager who will advise whether you can keep the gift, if it
should be returned to the donor or sold with the proceeds being donated to charity.
Under no circumstances should you accept any gifts of cash (or cash equivalents such as a bank cheque, money
orders, investment securities or payment of personal bills or expenses).
Visits from Government, Joint Venture, Public and State Owned Company Delegates
Due to the nature of our business, we sometimes receive visits from government, joint venture or state owned
company delegates to our offices or sites where we operate around the world. Whilst it is acceptable to promote,
demonstrate and explain the benefits of the services that Compass offers, there should be no attempt to influence
any decisions by offering personal benefits.
Gift and Hospitality records and
approval
All gifts, hospitality and business
meals which are offered to or by
Compass employees (whether
accepted or declined) must be
approved by your Line Manager. You
should keep a copy of all your
expense claims which will effectively
form a record of gifts or hospitality
that you provide. In addition, if you
are offered any gifts or hospitality
yourself, you must inform your Line
Manager so that a record can be
kept, regardless of whether or not you
accept the offer. All Line Managers
should keep a record of any gifts and
hospitality that is offered to them or
those that report to them. An
example of such a register is
available from the Group Legal
Department.
Prior approval from your Line
Manager must be sought before
agreeing to pay for any travel,
accommodation or expense costs of
any visiting government or state
officials.
14
PERSONAL INTEGRITY
Don’t forget, you can always discuss any concerns
or issues that you may have by contacting Speak
Up.

Competition and Anti-Trust
Compass takes its compliance with competition law – sometimes referred to as anti-trust law –
very seriously. Breaches of competition law will not be tolerated.
The laws on competition may vary from country to country and some laws can even apply to
business conducted outside the country of origin. The consequences of breaching competition
law can be severe for both companies and individuals. In the EU, a company can be fined up to 10% of its group
annual turnover for engaging in anti-competitive behaviour. In some countries including the US, Brazil, and the UK,
individuals found guilty of certain anti-competitive practices can receive prison sentences.
One of the factors that is often considered by the authorities when reviewing whether or not a company has acted in
an anti-competitive manner, is the market share that the company has. It is illegal in many jurisdictions to use anti-competitive
means to acquire or maintain a monopoly or dominant position. You should liaise with your local legal
team if the business area in which you operate has a significant market share.
In some countries, charging different prices to different customers can be considered anti-competitive. If you are
involved in setting prices for goods or services in your business area, you must familiarise yourself with the local
applicable law. Please speak to your local legal team for guidance.
NEVER:
 agree (or even discuss) with competitors the price at which Compass will sell goods or services;
 attempt to dictate to customers the price at which they resell goods or services supplied to them by Compass;
 automatically adopt suppliers' recommended retail prices - make your own pricing decision and record it;
 agree to artificially carve up a market i.e. by agreeing how customers/contracts with any non-Compass company
15
will be shared or by parcelling out different exclusive territories to each other;
 rig bids or tenders or have any communication with competitors in relation to any bids or tenders (except, for
instance, in connection with an official joint bid or joint venture being dealt with by your local legal team); and
 agree with any other company to artificially limit the production of goods or the supply of services.
DO NOT, WITHOUT FIRST CONSULTING YOUR LOCAL LEGAL TEAM:
 charge prices which are below total costs with the intention of pushing a competitor out of the market;
 refuse to supply an existing customer (except where the customer, for instance, refuses to pay bills);
 agree to exclusive contracts lasting for more than 5 years; and
 enter into agreements that give Compass "first refusal" for future foodservice and support services opportunities
on a given site.
Please note that you should consult with the Group Legal Department if you do not have a local legal team in the
country in which you operate.
Competition law regulates dealings
with competitors, customers,
distributors and other third parties
around the world. They prohibit
agreements, arrangements and
concerted business practices which
appreciably prevent, restrict or distort
competition (or have the intention of
doing so).
COMMERCIAL INTEGRITY
Q: We have been coming under some
pressure from clients to review our
contracts following the recent increase
in food costs, especially wheat. It would
be really helpful to understand what our
main competitors are doing, as we need
to remain competitive whilst ensuring
that we offer our clients the best price
that we can. Surely it is in our clients’
best interests if we can discuss this with
our competitors and come to some
general agreement?
A: It would be illegal for you to discuss pricing
plans or the possibility of fixing prices with
our competitors even if you do believe that
this would be of some benefit to our clients.
You would be placing yourself and the
company at serious risk of prosecution if
you were to do this, as well as causing
damage to Compass’ reputation.

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Competition and Anti-Trust (cont’d)
Trade Associations
Compass employees must be particularly cautious when considering joining a
trade association so as to ensure that they do not put themselves at risk of
engaging, or being perceived to engage, in any anti-competitive behaviour. You should not join a trade association
without the approval of your country Managing Director, who will refer the matter to the Group Legal Department for
confirmation. Employees are advised to maintain a careful record of any meetings with representatives of
competitors.
Trade Associations should not be used as a forum to agree a common approach to a commercial issue such as
price discounting. Even passive participation in meetings when discussions are taking place about, for example,
agreeing prices for the market, could place you and Compass at serious risk. You should make it clear that you are
not comfortable with the discussions and leave the meeting immediately. You should then report the matter to your
local legal team promptly.
If you are in any doubt about your participation at trade association meetings you should consult with your local legal
team.
Money Laundering
We are all expected to comply with money laundering prevention laws.
It is Compass’ policy not to accept payment for goods or services performed under contract from our clients (as
opposed to end-customers) in cash, travellers cheques, third party payments or money orders. We would usually
expect payments from clients to be drawn on bank accounts held in the name of the invoiced client.
Any payment that Compass makes to a supplier or other third party must also be made to a bank account titled in
the name of the contracted third party. Any exceptions to this must be pre-approved in writing by either your local
legal team or your Finance Director.
It is the responsibility of local management to ensure that Compass conducts its business in accordance with all
local legal requirements, including compliance with any currency reporting requirements.
Money laundering is the process by
which criminals attempt to hide and
disguise the true origin and ownership
of money gained through criminal
activities and can also refer to the
financing of terrorism. Money may be
filtered through a series of
transactions in order to “clean” it and
give it the appearance of being from
legitimate sources.
support regarding competition, anti-trust
issues and money laundering
from your local legal team or contact
the Group Legal Department. Full
contact details can be found in the
Business Conduct.
Q: One of our smaller clients has recently
contacted me to ask if they could settle our
invoice from a number of different
accounts. Is this okay?
A: You are right to check if this is acceptable. We
must be very careful about this kind of request
as it may indicate money laundering. Please
refer this matter to your Line Manager or local
legal team before responding to the client as
there may be a genuine reason for the client’s
request.

Bribery and Corruption
Bribery is the giving or receiving of a gift, payment or other benefit, in order to obtain a commercial advantage. A
bribe need not actually be paid – it is sufficient that it is asked for or offered. A bribe can be an issue irrespective of
whether it involves private industry or government.
Bribery or corruption in any form is unacceptable and we are committed to transparency in all our business dealings.
Most countries have laws that prohibit corruption. A breach of any of these laws is a serious offence which may
result in fines for Compass and imprisonment for individuals.
We are committed to creating a working environment in which all our people uphold the highest standards of
integrity and professionalism. This is particularly important in our dealings with governmental, federal, state, public
and local authority officials in any country.
You should always abide by the following basic rules irrespective of whether you are dealing with someone in private
industry or government:
 Never offer or make any unauthorised payments;
 Never attempt to induce anyone to do something illegal or improper;
 Always report any suspicions or knowledge of improper payments being offered or received; and
 Never offer or accept money (or anything of value), gifts or kickbacks, for obtaining contracts or business.
The Compass Group Fraud Policy
confirms the Group’s zero tolerance
approach to fraudulent, dishonest or
deceptive activities or behaviour and
is available on Mercury for all
employees to refer to as required.
You can also find a link to it in the
Reference section. The Code of
Ethics reinforces the Group’s overall
approach to doing business in an
ethical way. It is also available to all
employees on Mercury and a link to it
can be found in the Reference section
of the Code of Business Conduct.
17
Q: I am currently running a tender process
amongst suppliers for potatoes. One of
the potential suppliers has offered me
tickets to a big football game this
weekend. He cannot go but has said that I
can have two tickets and take a friend.
Can I accept these tickets?
A: You should be very wary about accepting
these tickets. As you are in the middle of a
tender process, you may be seen to be
accepting a bribe and invitations such as this
should be politely declined whilst the
tendering process is underway. You should
not offer or accept any gifts or hospitality
which may be seen to influence a business
decision. Please refer to the Gifts and
Hospitality Policy (a link to this policy can be
found in the Reference section of the Code of
Business Conduct) for further information.

18
Bribery and Corruption (cont’d)
Facilitation Payments
Facilitation payments are the payments of sums of money to a public official (or other person) as a way of ensuring
that they perform their duty either more promptly, or at all. For example, to secure the speedy release of goods held
in customs.
The giving of facilitation payments by Compass employees is prohibited. You should not make such payments, even
if they are for nominal amounts or are “normal” practice in the country in which you operate.
New Territories, New Sectors, Agents and Consultants
As part of our risk assessment procedure, the establishment of any business in a new country or territory in which
Compass does not currently operate, or the introduction of a new business sector/line into an existing country, must
first be approved by the Group Chief Executive and Group Finance Director using the procedure set out in the Group
Approvals Manual.
In addition to this, the process for the appointment of consultants and agents to act on behalf of Compass (which is
also set out in the Group Approvals Manual) has changed.
Please consult the Group Approvals Manual to understand the latest financial limits beyond which approval
must be sought. These have been significantly reduced since 1 February 2011.
You can find out more about our
policy on bribery and corruption by
making sure you are familiar with the
Code of Ethics (a link to this can be
found in the Reference section of this
Code of Business Conduct) and also
by seeking further guidance from your
local legal team
Q: We have been receiving an increasing
number of visits from government officials
who are responsible for issuing our health
and safety licences They expect to be
taken for dinner and have asked us for
cigarettes, and sometimes, cash. I am
worried that if I refuse them, they will not
issue our licences so we cannot operate
our business. What should I do?
A: Whilst it is imperative that we operate our
business units with all the correct licences and
approvals, the offering of gifts or cash to
facilitate the issuance of licences is strictly
prohibited. You should immediately report this
matter to your Line Manager.

Reporting and Accounting
It is essential that Compass records its financial and non-financial information in an
accurate and objective manner.
Financial Reporting
All books, records and accounts must conform with the Compass Accounting Policies and Procedures Manual. The
manual is a single reference source on compliance with International Financial Reporting Standards reporting for all
areas of the business and enables all Compass businesses to report under a single, clearly defined set of policies.
Remember the following basic rules:
 All records must be accurate and complete and they should allow an accurate view of the business at any point in
19
time;
 Supporting documentation should be collected at the time of a transaction;
 Accounting records and documentation should be retained in accordance with local legal and fiscal requirements,
but in any case, for not less than six years;
 Annual financial statements and documents relating to acquisitions and other significant transactions should be
kept permanently; and
 Fully co-operate with any internal or external audits, making sure that you provide the auditors with accurate
information and allow them unrestricted access to documents and colleagues (subject always to legal
constraints).
You must never:
 Falsify any record – financial or non-financial;
 Dispose or otherwise transfer any Compass assets without proper documentation and authorisation under the
Group Approvals Manual;
 Make any false or misleading accounting entries or expense claims; or
 Destroy information to conceal bad practices.
If you are concerned that correct financial processes are not being followed or that any kind of false or misleading
entries are being made, you should promptly report your concerns to your Line Manager. If you are uncomfortable
raising the matter with your Line Manager, consider speaking to your local Finance Director, HR or Speak Up.
support about accurate reporting and
accounts from your Line Manager,
local finance team or Group Finance.
The Group Accounting Policies and
Procedures Manual and the Group
Approvals Manual contain further
information and guidance on this
subject and can be accessed via
Mercury or via the links contained in
the Reference section of the Code of
Business Conduct.
Q: We have had a really successful half-year
and have exceeded our targets. We aren’t
expecting the next few months to be as
easy and I am wondering if I should book
some of our new client revenues into
next quarter’s figures to even out our
performance. I don’t think this will have a
negative impact on the client and I won’t
amend the actual figures. Is this okay?
A: No. Any activity aimed at shifting sales or
profit between reporting periods may result
in a misrepresentation of our financial
position and is unacceptable. Please ensure
that all reporting is accurate and not
misleading.

Data Privacy
As a business, Compass holds personal data about employees, our clients, suppliers
and other third parties. This information can be held in paper files as well as
electronically. It is crucial that we ensure that the confidential nature of any such
personal data is kept secure at all times.
In some countries, compliance with data privacy regulations is required by law and any
failure to comply could result in financial and criminal penalties for both Compass and the individual.
Any personal data that we hold must only be used for business purposes and we must ensure that it is:
 Obtained lawfully;
 Processed only for the purposes for which it was obtained;
 Accurate and relevant to the purpose;
 Not held for longer than is necessary;
 Stored securely; and
 Not transferred to other countries without adequate protection.
In addition to the above points, each of us has a responsibility to ensure that individuals who provide personal data
to us are made aware of who will have access to that data, and for what purpose.
Always abide by the following basic rules:
 Personal data should only be accessed by those authorised to do so, and only for business purposes;
 Personal data should never be provided to unauthorised persons in or outside of Compass without the necessary
consents and contracts in place to ensure that they also treat the personal data with the same level of
confidentiality; and
 Always ensure that personal data is held securely with restricted access.
If you receive any formal statutory or regulatory requests, or complaints from individuals to access personal
information that we are holding in respect of them, you must first refer the matter to your local legal team or whoever
locally is responsible for managing data protection issues.
You can get further support and
guidance about data privacy from
your Line Manager or local legal
team.
20
Q: I am looking to run a marketing campaign
in my local area to promote our new
support services offering. Can I use the
names and addresses held on our client
database to put together some mailings?
A: You must only send out marketing material to
individuals who have agreed to receive this
kind of information, otherwise you could be
breaching local data privacy laws. The data
held on a client database may have been
collated for a different purpose and so you
cannot assume that this is okay to use. You
should speak to your Line Manager or your
local marketing department for further
guidance.

Health and Safety
At Compass, our people will make us not just a good company to work for and do business
with, but a great company with a reputation for high standards and quality.
Our people are our most valuable asset. They are key to the success of the business. It's
every manager's responsibility to ensure that they lead in a way that nurtures, motivates and
inspires our people, without exception, to provide outstanding service for one another, our clients and our
customers.
It is our moral obligation to safeguard each other, our customers and the environment by operating an injury free,
healthy workplace serving food that is always safe to eat and that minimises our environmental impacts.
Health and safety remains our number one operational priority. All management meetings throughout Compass
feature a Health and Safety update as one of their first agenda items. Our Health and Safety policies are reviewed
by the Compass Group PLC Board on an annual basis to ensure that they continue to meet the needs of the
business and relevant legislation.
Compass is committed to providing a safe and secure working environment to all employees and to promote best
practice across Compass. We have developed a policy, minimum operating standards and behaviours which are
steadily being rolled out across the Compass business. Specifically we will:
 Seek to prevent injury to any employee, customer or contractor;
 Conduct a full risk assessment as soon as practicable when taking on any new contract;
 Consider the safety implications of our procurement decisions; and
 Ensure that every employee is properly trained to safely perform their work.
We also expect similar high standards from our suppliers and contractors.
We work hard to continually improve our health and safety performance and we have started to measure our
performance against a set of clear metrics to assure our customers and others who work with us that we are
operating the safest environment possible.
We believe that a commitment to safety requires a balanced approach from both management and employees.
21
EMPLOYMENT

EMPLOYMENT
Health and Safety (cont’d)
As part of this approach, Compass expects that management at all levels will:
 Ensure compliance with health and safety standards;
 Provide and maintain a safe working environment at all times;
 Develop, promote and implement company health and safety systems and practices;
 Effectively use Compass resources to meet our health and safety standards and objectives; and
 Train all employees to enable them to work in a safe and efficient manner.
In addition to the above, Compass expects all employees to:
 Display a “duty of care” for themselves and others in providing a safe working environment;
 Report any unsafe acts or conditions to their Line Manager promptly;
 Actively contribute ideas in order to make the workplace safer and more productive;
 Never walk away from an unsafe act or hazard. If you observe someone else performing an unsafe act, you
should explain to that person why it is unsafe and ask that they stop. If they refuse, it is your responsibility to
report this to your Line Manager;
22
 Not come to work under the influence of non-prescribed drugs or alcohol;
 Always wear the correct personal protective equipment;
 Make sure you know what to do if an emergency occurs at your place of work; and
 Follow safe work procedures at all times.
You can get further support or
guidance on health and safety
matters from your Line Manager, your
local HR team, local HSE team or
Group HSE.
Q: I am organising a large team of temporary
staff to help me at a forthcoming sporting
event. We are really tight on time and
expect to be incredibly busy. I’m planning
on cutting out the health and safety talk
and emergency procedure as most of the
temporary staff have worked for me before.
Is this okay?
A: No. We all have a responsibility to ensure a
safe and secure working environment for
everyone who works for Compass. It is
important that you spend a few minutes
briefing the team and outlining the procedure
to follow in the event of a fire or other
emergency.

EMPLOYMENT
Fair Treatment and Equal Employment Opportunities
Compass respects and values the individuality and diversity that every
employee brings to the business and we seek to create a positive, open
working environment wherever we operate.
In relation to our employees:
 We are committed to basing our relations with our employees on respect for the dignity of the individual and fair
23
treatment for all;
 We aim to recruit and promote employees on the basis of their suitability for the job without discrimination; and
 We do not tolerate any form of discrimination or sexual, physical, mental or other harassment of any kind towards
our employees.
To help us achieve our aims we have developed a simple framework of objectives, measures and actions that focus
on the five key areas of people management and development:
 Attract – recruiting the right people, in the right way and reflecting the diversity of the communities that we work
in;
 Retain – having the right rewards and benefits and work environment for people to want to stay with us;
 Develop – ensuring that people have the right skills to do their job and develop careers with us;
 Engage – connecting all our people to our goals, motivating them to achieve them and recognising their
achievements; and
 Perform – having the processes in place to manage and continually improve individual performance.
As an employee you must:
 Treat your colleagues fairly and with dignity and respect. Discrimination of any kind will not be tolerated;
 Follow all applicable labour and employment laws in the country in which you work. Make sure you are familiar
with any applicable local legislation – speak to your local HR department for further guidance; and
 Report any instances of breaches of our commitment to equal opportunities. Do not be afraid to speak up – we
all have a responsibility to address issues that we become aware of.
guidance about the fair treatment and
equal opportunity principles under
which we operate from your Line
Manager, local HR team or Group
HR.
Q: I recently applied for a new role in our
business which would have been a
promotion for me. I did have an interview,
together with four other internal
candidates but I did not get the job. I was
told “unofficially” that they are looking for
a man for the role as there is some
international travel requirements and they
don’t think female employees would be
willing or able to leave any young family.
What can I do?
A: It is unacceptable for you to be discriminated
against because of your gender. All
candidates for vacancies should be judged on
their qualifications and suitability for the role.
You should raise this with your Line Manager
or HR team. If you feel uncomfortable doing
this, you could contact Speak Up.

EMPLOYMENT
Working without Harassment/Bullying
We expect that all employees should be treated fairly and with respect. We will not tolerate harassment or bullying
of any kind in the workplace against our employees – or our suppliers, business partners or clients.
Please make sure you always abide by these basic rules:
 Do not make jokes about race, ethnicity, religion, age or sexual orientation;
 Do not distribute, display or keep on company property any material which could be considered offensive
24
including emails, cartoons, photos etc;
 Do not spread malicious rumours or use email, voicemail or other means to transmit derogatory or discriminatory
comments; and
 Always treat personal information as confidential. Do not misuse it; and remember:
 Offensive, intimidating, insulting or malicious behaviour of any kind will not be tolerated.
All forms of harassment or abuse are against company policy and will not be tolerated. If you are being bullied or
harassed, or are aware that someone else is, please speak to your Line Manager or another senior member of staff.
Alternatively you can call Speak Up.
guidance about working without
harassment and bullying from your
Line Manager, local HR team or
Group HR.
Q: Some of my colleagues at work have been
making fun of my accent. I appreciate that
this started off as harmless fun but the
comments have become more personal and
I find this quite upsetting. I don’t want to
get anyone into trouble but I would really
like it to stop. What should I do?
A: We would encourage you to speak with your
colleagues and explain the effect that their
behaviour is having on you. If you feel
uncomfortable doing this, or this does not stop
their behaviour, you should speak to your Line
Manager or HR. Discrimination of any kind
should not be tolerated.

COMPANY ASSETS
Brand Protection
Our reputation is a key factor in attracting clients and consumers to Compass and it is
imperative that the value and goodwill in this reputation is appropriately protected and
promoted by, amongst other things, taking steps to manage and protect our brands
properly.
As a market leader in the foodservice and support services sector, we often produce recipes, processes, non-public
ideas and strategies that belong to Compass and which we must protect. The use made of a trade mark in
connection with our business and services builds significant goodwill, reputation and brand value. We must also
protect other confidential business information, such as customer data and personnel information and ensure that it
is kept confidential.
In addition, our trade secrets, such as information contained in the Compass Service Framework or recipes and
process maps, help distinguish us from our competitors and maintain a competitive advantage in the market place.
You should consult with your local legal team if you are considering developing a new brand or technology where
you wish to rely on intellectual property rights. Please also refer to the Compass Group Intellectual Property Policy
(a link to this can be found in the Reference section of the Code of Business Conduct).
Always remember the following basic rules:
 Never agree to assign our intellectual property rights to clients, customers or other third parties without first
25
consulting with your local legal team;
 Do not agree to share any of our intellectual property or confidential information without first making sure an
approved confidentiality agreement is in place. Seek advice from your Line Manager or your local legal team if
you are unsure; and
 Never use Compass intellectual property or confidential information for personal gain or for reasons unconnected
with your role at Compass.
We are committed to respecting the intellectual property and confidential information of third parties. You must follow
these basic rules:
 Only copy documents and materials when you have specific permission to do so;
 Do not knowingly infringe a patent, trade mark or other intellectual property right of any third party. Please seek
advice from your local legal team if you are in any doubt;
 Do not use any third party’s confidential information unless you are authorised to do so in a signed confidentiality
agreement that meets local internal guidelines; and
 Do not load any unlicensed software on any Compass computer or other equipment.
If you have any questions, please speak to your Line Manager or seek advice from your local legal team.
guidance on brand protection from
your Line Manager, local marketing
team, Group Market Development
team or the Group Legal Department.
Q: I have recently joined Compass from one of
their major competitors. Before I left, I took
copies of some purchasing data, including
pricing information, which I think could
really be beneficial to my new team. Surely
using this information will be in the best
interests of Compass?
A: No! Not only are you likely to be breaching your
obligations of confidentiality to your previous
employer and the principles contained in the
Code of Business Conduct, you may well be
breaking the law. You must not bring or use
any confidential information from any previous
employer. This does not mean that you cannot
use any general knowledge or skills that you
have learnt at any previous employer. If you
are in any doubt, please check with your local
legal team.

COMPANY ASSETS
Confidentiality
No employee should disclose any confidential information relating to any Compass company or its business outside
the Group without specific authority to do so.
Where confidential information is to be disclosed to another party, it should be released only under the terms of a
written confidentiality agreement or undertaking entered into with the other party.
If you are required to disclose confidential information under the terms of an order of any competent judicial,
governmental, regulatory or supervising body, you should first notify your local legal team and seek their approval
before making the disclosure.
Employees should not use Compass’ confidential information for their own personal advantage or for a friend or
relative.
You should also make sure that you are familiar with your local IT policy and follow its guidelines in terms of security
and the use of Compass IT systems. Please remember that the company many monitor and record your use of the
IT systems at any time and without prior notice.
Physical Assets
We all have a responsibility to ensure that Compass property that we use or come into contact with as part of our
work is not damaged, misused or wasted. We also have a responsibility to report the abuse of Compass property by
others.
Please also make sure that any Compass property that you use is well maintained so that it can be operated safely
and properly.
Confidential information is any
information or knowledge, the
disclosure of which outside Compass
might be prejudicial to the interests of
Compass . Examples include (but are
not limited to):
 new product or services
26
development material;
 unpublished financial data;
 business ideas, processes or
strategies;
 sales, marketing and other
corporate databases; and
 personnel data.
guidance on issues of confidentiality
legal team or the Group Legal
Department.
Q: When I was taking out some papers to be
recycled I found a bag with lists of
employees and payroll information on it. I
am concerned that this information could
have been seen by anyone. What should I
do?
A: You should take the papers to the HR
department and report the matter to your Line
Manager or HR. We are all responsible for
maintaining the security and privacy of
confidential information and you are right to be
concerned by what you have found. The HR
department will ensure that the papers are
securely destroyed and make sure that
whoever left the papers there is reminded of
their duties in this regard.

COMPANY ASSETS
Information Security
Compass’ systems - that is our IT hardware, software, office equipment, telephone
and email system - are all intended to be used for conducting Compass business.
Each user is required to use the facilities in a professional and responsible manner at
all times.
In order to protect both Compass and individuals using our IT systems, you should always ensure that your use of
the Compass IT systems:
 does not break the law in the country where you are working;
 does not risk bringing the Compass name into disrepute; and
 does not cause damage or disruption to Compass’ business.
In certain circumstances, misuse of either the internet or email can constitute a criminal offence. Each of us has a
responsibility to ensure we understand the legal restrictions that apply in the country where we are working, and
make sure we adhere to them. Please speak to your local legal team for further guidance on legal restrictions that
may apply in the country where you work.
Please make sure you always follow these basic rules:
 do not install or use any unauthorised hardware or software on any Compass system;
 protect any username or password that you are allocated and do not share them with others;
 do not access or download, create or forward emails, documents or images that may cause offence, distress or
27
harassment to others;
 restrict your use of Compass systems for personal use to a minimum; and
 make sure you save and back up regularly any data or work that you hold on your system in accordance with the
advice of your local IT team.
This guidance must be read in
conjunction with the Compass IT
Acceptable Use Policy (which can be
accessed via Mercury). A link to this
policy can also be found in the
Business Conduct. If you are unclear
on any issue please speak to your
Line Manager.
Q: I run a small business from home at the
weekend selling handmade jewellery.
There is no conflict between this and my
work for Compass (I have checked this with
my Line Manager) and usually it does not
impact on my work. I have a rush of orders
at the moment and would like to spend my
lunch break accessing my website to check
some customer orders. Is this allowed?
A: Whilst Compass does permit brief and
occasional personal use of the internet, our
policy does not permit employees using the
internet at work for any personal monetary
interests or gain. You must run your “home”
business at home.

EXTERNAL ACTIVITY
Dealing with Governments and Public Regulatory Bodies
You may come into contact with government officials or representatives from
public regulatory bodies during the course of your work for Compass. If you
are asked to provide them with any information in connection with an enquiry
or investigation, you have a duty to make sure that you are truthful and
accurate, and that Compass’ legitimate interests are protected.
Always contact your local legal team before responding to any request for information from an unexpected agency.
You should make sure that any information or files relevant to the investigation are preserved and not destroyed.
This includes making sure any electronic systems for record disposal are temporarily suspended to ensure that
relevant records are kept.
Compass employees are expected to co-operate fully with the investigation. You must not obstruct the collection of
information by properly authorised officials or retaliate against anyone who co-operates with the investigation.
If government officials attend your office or unit and request information, please make sure you follow these basic
rules:
 contact your local legal team immediately;
 ask to see identification and take a copy of it;
 clarify with the individuals which organisation they are representing, what is the nature of their investigation; and
 make sure that the representatives are not left unattended.
You should contact your local legal team if you have any doubts and make sure that you are familiar with the
required local procedure in the event of dealings with local government and public regulatory bodies.
guidance on issues of confidentiality
legal team or the Group Legal
Department.
28
Q: In my previous company, we were advised
to not give out any information to any
external parties, regardless of who they
were. I don’t want to get in trouble for
breaching confidentiality. What is the
correct thing for me to do?
A: The first thing you should do is contact your
local legal team – they will advise you on what
information can and cannot be given to any
third party.

EXTERNAL ACTIVITY
Community and Charitable Activity
Success in business is dependent on compliance with legal constraints, together with
sensitivity to local customs and conventions governing business relationships. The
communities in which we operate (and from which we draw our employees) are
important to us.
Compass is committed to making a positive contribution to the sustainable development of the communities in which
we operate. We strive to take into account the concerns of the wider community – including national and local
interests – in all of our operations. We use our expertise to contribute to the wellbeing of the community in a manner
appropriate to our business objectives.
Respecting the cultures and local customs of other communities and countries and always following local laws is
important. Certain business practices which may be acceptable in one country could be unacceptable in another.
Being aware of the differences may affect the way you need to do business.
All Compass employees are expected to abide by the following basic rules:
 always respect the culture and business customs of the communities and countries in which you are working
29
(providing that they do not conflict with the principles contained in the Code of Business Conduct);
 always comply with local laws and regulations – contact your local legal team if you need assistance in this
regard; and
 always keep your Line Manager informed about any planned communication with designated non-governmental
agencies and seek their approval before engaging with such parties.
Through its donations and sponsorships, Compass aims to improve its impact on the environment in which it
operates and the communities it serves to benefit all of its stakeholders.
Compass has an approvals process
which must be followed before any
charitable donations can be made.
Please familiarise yourself with the
Compass Charitable Donations Policy
(a link to which can be found in the
Business Conduct).
Any charitable contribution provided
by a Compass company must be fully
documented in your company books,
and where required by law, placed on
the public record either by Compass
or the recipient.
guidance on our community and
charitable activities from your Line
Manager, your local legal team or the
Group Legal Department.
Q: I have been approached by a client who has
asked us to host a charity dinner at our
restaurant. Am I able to do this?
A: Please speak to your Line Manager before
agreeing to help. Compass encourages the
support of community and charitable activities,
but it is important to ensure that the approvals
process is followed, particularly as the request
has come from a client.

EXTERNAL ACTIVITY
Political Activity
As part of doing business, Compass sometimes engages with government 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.
It is not Compass policy to make donations to any political parties. However, it is possible that certain routine
activities undertaken by Compass might unintentionally fall within the broad scope of the UK legal provisions
controlling political donations and expenditure that we must adhere to. Any such expenditure must first be approved
by Compass Group PLC shareholders and will be disclosed in the annual report.
Compass employees must not engage in lobbying or have contact with legislators, political candidates, regulators,
government employees or public interest groups, unless they are doing so under the guidance of Group Media
Relations, Group Investor Relations or the Group Legal Department. Please refer to the Corporate Communications
Code (a link to this can be found in the Reference section of the Code of Business Conduct) for further details.
Please make sure you follow these basic rules:
 Do not seek to make a donation on behalf of Compass to any political organisation which promotes party political
30
activities;
 Please keep any personal political activities separate from your work and do not use company time and
resources to support them – please refer to the Conflict of Interest section of this Code for further information;
and
 Make sure you engage with the Group Head of Media Relations, Group Investor Relations or the Group Legal
Department before you make contact with any government, regulators, legislators or lobby groups on behalf of
Compass.
guidance on issues about Compass’
political activity from your Line
Manager, your local legal team or the
Group Legal Department.
Q: I have been contacted by a lobbying group
who are making a short film about the
environmental impact of disposable cups. I
think this could really help promote our
excellent reputation for environmental
issues. I believe they are intending to take
this film to government. Does this mean I
can’t take part in the film?
A: You are right to question this. You should get
in touch with the Group Head of Media
Relations and discuss the proposal in more
detail with them. They, together with the Group
Legal Department, can advise you on how you
can respond and what level, if any, of
involvement you can have.

EXTERNAL ACTIVITY
External Communications
As part of our daily work we may come into contact with key “stakeholders” –
this would include employees, business partners, clients, customers, investors,
the media, communities and governments. It is crucial that our stakeholder
communications are managed in accordance with the Compass
Communications Code.
You must never talk to reporters or investment analysts about Compass business, either formally or informally. Only
nominated people are authorised to speak to external audiences, such as the market, analysts, investors and the
press. This means:
 Our Chief Executive Officer, Group Finance Director and Compass Group PLC main Board directors;
 Director of Corporate Strategy, Investor and Media Relations;
 Group Head of Media Relations;
 Group General Counsel and Company Secretary; and
 Other people expressly authorised by one of the people listed above.
Contact details for the above persons can be found in the Reference section of the Code of Business Conduct. All
other employees are prohibited from giving significant information to anyone outside of Compass without prior
written approval from an authorised person. If you are approached by any external party to give information about
our business, you should re-direct the enquiry to an authorised person in the first instance.
Operating companies are not permitted to release any statement, press release or presentation internally or
externally, which may contain or amount to inside information (that is information that is likely to have a significant
effect on the price of Compass Group PLC’s shares) without prior approval from Group Investor Relations who will
arrange for a release to the markets. Please also refer to the Insider Trading section of the Code of Business
Conduct for further guidance.
The Compass Communications Code
is provided to ensure the seamless
flow of communication within
Compass and its internal and external
audiences. A link to this can be found
in the Reference section of the Code
of Business Conduct.
g u i d a n c e abo u t e x t e r n a l
communications from your Line
Manager, your local legal team or
Group Investor and Media Relations
team or the Group Legal Department.
31
Q: I noticed an article in a newspaper over the
weekend about Compass which contained
some inaccuracies. Can I contact the paper
and ask them to correct their report?
A: It is great that you are alert to this kind of
matter but please do not contact the
newspaper yourself. Any media
communications should be handled via the
Group External Communications team. Their
contact details can be found in the Reference
section of the Code of Business Conduct.

EXTERNAL ACTIVITY
Environment
The environment is not a sector, but an attitude and approach which represents
a necessary part of all of our activities. In short, it is important that everyone
displays environmental responsibility in all areas within their control, regardless
of their position.
As one of the largest food service companies in the world, Compass recognises that it has an impact on the local
environments in which it operates and the global environment in general.
In addition to complying with all relevant environmental legislation, Compass has developed its own common set of
behaviours that are being introduced into all our operations. We continue to drive improvement across our business,
particularly in the areas of supply chain and environmental performance.
In the majority of our locations where we are not directly responsible for the procurement of utilities, equipment, fuel
etc., we work closely with our clients to consider how best to improve the environmental performance of our
operations.
Basic rules you must follow:
 All employees must comply with company rules and procedures in relation to environmental matters;
 Ensure that you are equipped with the right information, training and tools necessary to implement responsible
32
environmental practice;
 Make sure you prevent or minimise any release of pollutants into the environment as a result of your work
activities;
 Make sure you properly dispose of all waste materials and have due regard to good waste management practice.
You should be aware of the best environmental option for the disposal of particular waste materials in your
workplace. Any employee found to have disposed of waste material in an appropriate or illegal manner may be
subject to disciplinary action;
 All employees should consider energy efficiency in all aspects of their work and take steps to save energy
wherever practicable;
 All employees should use recycled materials in their work activities wherever available and should recycle any
appropriate items in line with local or national recycling schemes that may be available; and
 All employees should ensure that they do not carry out activities that waste water.
By environment we mean anywhere
that might be affected by what we do,
such as:
 our immediate surroundings
which might be affected by noise,
smells and fumes;
 the local environment which might
be affected by pollution, traffic
and disposal of our waste; and
 the global environment which
might be affected by using energy
from fossil fuels or using certain
chemicals which damage the
atmosphere.
guidance on environmental issues
legal team or HR. You can also find a
link to our Environmental Policy
Statement in the Reference Section
of the Code of Business Conduct.
Q: Will I be penalised if I raise concerns about
health and safety in the unit where I work?
We have been told to dispose of used
cooking oil by pouring it down the drains
outside.
A: Compass’ number one priority is health and
safety. If you have any concerns about health
and safety issues you should report them to
your Line Manager at once and if appropriate,
stop work or refrain from the activity that is
causing you concerns. If you are
uncomfortable speaking to your Line
Manager, you can contact your local legal
team, HR or Speak Up. We will not tolerate
any kind of retaliation against anyone who
raises any concerns.

33
REFERENCE SECTION
Links to Policies and Further Information
Publicly Available Documents on the Compass Group PLC website
(www.compass-group.com)
1. Code of Ethics
2. Food Safety Policy Statement
3. Environmental Policy Statement
4. Purchasing & Supply Chain Statement
Documents for Internal Purposes Only (please do not distribute externally)
downloadable from the Policies section on Mercury
(http://mercury.compass-group.com)
1. Compass Group Fraud Policy
2. Compass Group Gifts & Hospitality Policy
3. Compass Group Intellectual Property Policy
4. Compass IT Acceptable Use Policy
5. Compass Group Charitable Donations Policy
6. Group Communications Code
7. Compass Group Speak Up Programme
8. Group Approvals Manual
9. Compass Accounting Policies and Procedures Manual

34
REFERENCE SECTION
Contacts
Group Legal Department
Mark White Group General Counsel & Company Secretary +44 (0) 1932 573006
mark.white@compass-group.co.uk
Stuart Pain Deputy General Counsel +44 (0) 1932 573013
stuart.pain@compass-group.co.uk
Group HR
Jane Kingston Group HR Director +44 (0) 1932 573103
jane.kingston@compass-group.co.uk
Internal Audit
Trevor Gelnar Director of Group Internal Audit +44 (0) 1932 573158
trevor.gelnar@compass-group.co.uk
Corporate Strategy, Investor & Media Relations
Sarah John Director of Corporate Strategy, Investor and Media Relations +44 (0) 1932 573064
sarah.john@compass-group.co.uk
Internal Communications
Katie Burke Group Internal Communications +44 (0) 1932 574173
katie.burke@compass-group.co.uk
Group HSE
Nicki Crayfourd Director of Health, Safety & Environment +44 (0) 1932 573141
Nicki.crayfourd@compass-group.co.uk
Other
Speak Up
www.compass-speakup.com

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