REGISTRATION

DOCUMENT

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This document is a free translation of the original, which was prepared in French. All possible care has been taken to ensure that the translation is an accurate representation of the original. However, in all matters of interpretation of information, views or opinions expressed therein, the original language version in French takes precedence over this translation.

Universal Registration Document

Annual Financial Report

Fiscal 2019-2020

Société anonyme (French joint-stock corporation)

Share capital: €1,741,478.23

Registered office:

9-11 allée de l'Arche

92032 Paris La Défense, France

Registered in Nanterre under no. 408 168 003

The original French-language version of this Universal Registration Document (the Document d'Enregistrement Universel) was filed on January 12, 2021 with the Autorité des Marchés Financiers (AMF) in its capacity as the competent authority as defined in Regulation (EU) 2017/1129, without prior approval as provided for in Article 9 of said Regulation.

The Document d'Enregistrement Universel may be used in support of a public offering of securities or the admission of securities to trading on a regulated market if accompanied by a securities note and, where applicable, a summary and all amendments to the Document d'Enregistrement Universel filed since it was first approved. The prospectus formed by these documents must be approved by the AMF in accordance with Regulation (EU) 2017/1129.

Copies of the Document d'Enregistrement Universel in French and the English translation thereof (the Universal Registration Document) may be obtained free of charge from Elior Group's registered office, or may be downloaded from the websites of Elior Group (www.eliorgroup.com) and the AMF (www.amf-france.org).

An e-accessible version of this document is available at www.eliorgroup.com

UNIVERSAL REGISTRATION DOCUMENT . ELIOR GROUP . 1

NOTE

General Information

This universal registration document (hereinafter referred to as the "Universal Registration Document") also constitutes:

  • the annual financial report that must be drawn up and published by all listed companies in France within four months of their fiscal year-end, in accordance with Article L. 451-1-2 of the French Monetary and Financial Code and Article 222-3 of the General Regulations of the AMF; and
  • the annual management report issued by Elior Group's Board of Directors that must be presented at the Annual General Meeting held to approve the financial statements for the past fiscal year, in accordance with Articles L. 22-10-34et seq. of the French Commercial Code.

In the Universal Registration Document, the term "Company" refers to Elior Group SA, and the terms "Group", "the Elior group" and "Elior" refer to the Company and its consolidated subsidiaries as a whole.

Forward-Looking Statements

This Universal Registration Document contains various forward-looking statements regarding the Group's outlook and growth prospects. Words such as "expect", "anticipate," "assume," "believe," "contemplate,"

"continue," "estimate," "aim", "forecast," "intend," "likely," "plan," "positioned," "potential," "predict," "project," "remain" and other similar expressions, or future or conditional verbs such as "will", `should", "would" "could", "may", or "might", or their negative equivalents identify certain of these forward-looking statements. Other forward-looking statements can be identified in the context in which the statements are made. These statements do not reflect historical or present facts or circumstances. They are not guarantees of future performance and they involve uncertainties and assumptions on matters that are difficult to predict. These forward-looking statements are based on information, assumptions and estimates considered reasonable by Group management. They may change or be amended due to uncertainties related to, among other things, the economic, financial, competitive and/or regulatory environment. Forward-looking statements are included in a number of places in this Universal Registration Document, and consist of statements related to the Group's intentions, estimates and objectives concerning, among other things, its markets, strategy, growth, results, financial situation and cash position. The forward-looking statements in this Universal Registration Document are to be understood as at its filing date, and the Group does not accept any obligation to update forward-looking statements to reflect subsequent changes affecting its objectives or any events, conditions or circumstances on which the forward-looking statements are based, except to the extent required by the applicable laws and regulations.

2 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

CONTENTS

1.THEELIORGROUP5

1.1 Interview with Gilles Cojan, Chairman of the

Board of Directors

5

1.2 Interview with Philippe Guillemot, Chief

Executive Officer

6

1.3

Selected financial information

8

1.4

Information about the Group

12

1.5

Organizational structure

14

1.6

The Group's business model

16

1.7

The Group's businesses and strategies

18

1.8

Elior Group on the stock market

50

2.CORPORATESOCIALRESPONSIBILITY

56

2.1 Corporate social responsibility: a value-

creation driver

56

2.2

Conducting business responsibly

62

2.3 Promoting a tasty, healthy and sustainable

diet

66

2.4

Responsible procurement

72

2.5

A circular model

76

2.6 Ensuring employees' health, safety and

development

81

2.7

Methodological note

87

3.CORPORATEGOVERNANCE-AFR

99

3.1

Administrative and management bodies

99

3.2

Risk management

174

3.3

Employees

192

4.MANAGEMENT'SDISCUSSIONANDANALYSISFOR

FISCAL2019-2020-AFR

195

4.1

Significant events

195

4.2 Analysis of the Group's business and

consolidated results

197

4.3 Consolidated cash flows for the years ended

september 30, 2019 and 2020

204

4.4

Simplified consolidated balance sheet

207

4.5

Events after the reporting date

208

4.6 Main disclosure thresholds crossed during the

year ended September 30, 2020

209

4.7

Parent company net profit and dividend 212

4.8 The Group's financial and liquidity position213

4.9

Outlook

221

4.10 Consolidated financial statements for the years

ended September 30, 2020 and 2019

222

4.11 Statutory auditors' report on the consolidated

financial statements - AFR

285

4.12 Separate financial statements of the parent

company for the year ended September 30,

2020

290

4.13 Statutory auditors' report on the parent

company financial statements - AFR

304

4.14 Statutory auditors' special report on related-

party agreements

309

5.INFORMATIONABOUTTHECOMPANYANDITS

SHARECAPITAL312

5.1

Information about Elior Group SA

312

5.2

Information about the share capital - AFR

321

5.3 The Company's ownership structure - AFR 329

6.ADDITIONALINFORMATION

338

6.1

Material contracts

338

6.2

Documents available to the public

339

6.3 Persons responsible for the Universal Registration Document and the audit of the

accounts - AFR

340

6.4

Information incorporated by reference

342

6.5 Third party information, statements by experts

and declarations of any interests

343

6.6 Cross-reference table for the universal

registration document

344

6.7 Cross-reference table for the annual financial

report

348

6.8 Cross-reference table for the management

report

349

NB: The sections of this document that constitute the Annual Financial Report are identified by the letters AFR in the contents table (see also cross-reference table in Chapter 6, Section 6.7).

UNIVERSAL REGISTRATION DOCUMENT . ELIOR GROUP . 3

1

THE ELIOR GROUP

1.1 Interview with Gilles Cojan, Chairman of the

Board of Directors

5

1.2 Interview with Philippe Guillemot, Chief

Executive Officer

6

1.3

Selected financial information

8

1.3.1

Key performance indicators

8

1.3.2

Key figures

9

1.4

Information about the Group

12

1.5

Organizational structure

14

1.5

Organizational structure

14

1.6

The Group's business model

16

1.7

The Group's businesses and strategies

18

1.7.1

Businesses

18

1.7.1.1 Contract catering

18

1.7.1.2 Services

20

1.7.1.3 Market trends

20

1.7.2

The Group's strategy

28

1.7.2.1 Key features of the contract catering

market

28

1.7.2.2 Key features of the services market

29

1.7.3

The Group's competitive strengths

29

1.7.3.1 An operating presence in growing markets

with attractive fundamentals

29

1.7.3.2 Carefully chosen strategic fit between

contract catering and services

30

1.7.3.3 A resilient business model thanks to a loyal

client base and long-term contracts

32

1.7.3.4 A proven capacity to create value, combining

organic and acquisition-led growth and a

recognized ability to effectively integrate

acquired companies

33

1.7.3.5 Operating excellence resulting from a tightly-

controlled supply chain and cost base

33

1.7.3.6 Experienced management teams with an

entrepreneurial mindset and in-depth

knowledge of their markets

34

1.7.4 The Group's main operating markets

35

1.7.4.1 The business & industry market

35

1.7.4.2 The Education market

36

1.7.4.3 The Health & Welfare market

37

1.7.5

Geographic markets

38

1.7.5.1 Contract catering in France

38

1.7.5.2 Services in France

38

1.7.5.3 International contract catering

39

1.7.6 Laws and regulations applicable to the Group

40

1.7.6.1 Food safety regulations

40

1.7.6.2 Labor and employment laws and

regulations

46

1.8

Elior Group on the stock market

50

1.8.1 Financial communications and shareholder

relations

50

1.8.1.1 Preparation of financial communications

50

1.8.1.2 Fiancial communications policy

50

1.8.1.3 Regular contacts with shareholders and

investors

50

1.8.1.4 A steady flow of informations

50

1.8.2 The Elior Group share

52

4 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

1. THE ELIOR GROUP

1.1 INTERVIEW WITH GILLES COJAN, CHAIRMAN OF

THE BOARD OF DIRECTORS

The Covid-19 pandemic that has swept the globe over the past several months has left no organization untouched, both from a human and economic perspective. How has Elior dealt with this unprecedented situation?

During this exceptional global crisis, Elior has demonstrated the solidity of its operations teams, the strength of its governance and the power of its values. After a good start to the fiscal year, our business was impacted by the outbreak of the pandemic as from the month of March in all of our host countries. But we swiftly moved into action to adapt to the new reality, with our first priority being to protect the health and safety of our employees, clients and guests. We also immediately took steps to safeguard our financial flexibility and maintain our strict cost discipline, all the while continuing to support our clients.

I would like to take this opportunity to thank all of the Group's teams for the outstanding dedication and commitment they have shown, led by the Executive Committee and fully backed by the Board of Directors. We were able to quickly implement measures designed to ensure our clients could continue their operations, without ever shifting our focus from our fundamental role as a socially responsible caterer, or losing sight of our long-term vision. The crisis has clearly highlighted the expertise of our Services teams, who have displayed an incredible level of resilience, particularly in supporting healthcare workers.

What is your overall view of fiscal 2019-2020?

During these turbulent times, we have demonstrated a strong command of our operations and proved that we made the right strategic choices in 2019 with the launch of the New Elior 2024 plan, spearheaded by Philippe Guillemot. The sale of Areas gave us the resources to face the crisis with a solid financial basis. And thanks to our strict cash management we have remained financially robust despite our revenue being hit by the crisis. Our clients' trust in us is apparent in the many new contracts and contract renewals we won throughout the year, which in turn has reinforced our resilience. And our work on transforming our business, particularly digital

transformation, is well under way in all of our markets - Education, Business & Industry, Health & Welfare and Services - and in each of our host countries.

Today, Elior is a group refocused on its core business, with solid fundamentals and the agility to meet the new expectations of its clients and guests. It is concentrated on a long-term vision shaped by the deep-seated changes taking place in its markets. I firmly believe we are very well positioned to emerge from the Covid-19 crisis stronger than ever and prepared for the future.

So what do you think the main challenges will be in 2020-2021?

For 2020-2021, over and above the repercussions of the pandemic, Elior's objective remains unchanged, namely sustainable and profitable growth. To achieve this, our main challenge will be to reinvent each of our businesses by channeling our value proposal even more closely towards our expertise as a caterer dedicated to providing healthy, delicious and environmentally-friendly food. We are convinced that these unprecedented times will accelerate the pace of change in the markets we serve.

For all of these reasons, we have already embarked on putting in place cutting-edge culinary, digital and marketing innovations. Our agility in proposing new offerings that meet the expectations of our clients and guests, combined with our expertise in hygiene and safety, will enable us to rise to the challenges that lie ahead and keep up our growth momentum.

The Board of Directors will fully play its role by supporting the Executive Committee and all of Elior's teams as they implement these transformational changes. And I have every confidence that, together, we will carry them through successfully.

UNIVERSAL REGISTRATION DOCUMENT . ELIOR GROUP . 5

  • The Elior Group

Interview with Philippe Guillemot, Chief Executive Officer

1.2 INTERVIEW WITH PHILIPPE GUILLEMOT, CHIEF

EXECUTIVE OFFICER

Last year you presented the New Elior 2024 strategic plan. But that was before the Covid-19 pandemic struck. So is the plan still relevant today?

Yes it is - more than ever in fact. First, because the outbreak of Covid-19 proved we made the right strategic choices in 2018-2019, particularly our sale of Areas, which put us in a strong financial position to weather the crisis. And second, because the pandemic has fast-forwarded the market trends we've been anticipating for the past few years, which were already central to our New Elior 2024 strategy.

I'm convinced we have to remain true to our fundamental values as a socially responsible caterer and services provider if we're going to meet the challenges that lie ahead. In other words, we have to continue to earn the trust of our guests each and every day by serving them healthy, balanced and environmentally-friendly food, and taking care of our clients' sites and work environments through our services business in France. In these unprecedented times, we shouldn't be changing course but, on the contrary, we need to stay firmly on course and even step up the pace by making high-impact changes in each of our markets.

How has the Elior group handled the past months marked by the Covid-19 crisis?

I'd like to take this opportunity to pay tribute to all of our people at Elior, whose commitment has been truly amazing. Faced with the pandemic, our Group has not only shown great control, but has also demonstrated its strong sense of responsibility and solidarity - values that are deeply rooted in our DNA.

As from February in Italy, and then in all of our host countries (the United States, India, Spain, the United Kingdom and France), our teams adapted by sharing best practices, and took up their place on the front line alongside our guests, clients and partners. In each of our geographic regions, in both catering and services, in our kitchens, at our sites, or working from home, they moved into action alongside the carers, key workers and organizations who were counting on us to help them continue their activities.

Drawing on our strong regional presence, our teams also showed their commitment by helping local vulnerable communities through numerous support measures. For example, during the lockdown period they organized donations of surplus food and distributed meals to disadvantaged people, the vulnerable elderly and other shielders, as well as schoolchildren from low-income families. I want to personally thank them for their drive and dedication. They are a real credit to us as a socially responsible company.

At the same time, we took great care to offer tailored, scalable solutions, all the while calibrating our organizational structure, catering offerings and services in such a way as to maintain the financial equilibrium that is indispensable for the Group's profitability.

How would you sum up fiscal 2019-2020?

Faced with exceptional circumstances, we swiftly executed a coordinated Group-wide action plan. Our adaptability, flexible organization and strict cost management helped us maintain a high level of liquidity. And thanks to our solid economic and financial fundamentals, expertise in hygiene and food safety, and teams dedicated to the well- being of our clients and guests, we were able to meet the challenges of both the first and second waves of Covid-19.

Business remained brisk in Health & Welfare, Education, and Business & Industry excluding the white-collar sector, both for contract catering and services. In parallel, we stepped up the rollout of new food service offerings, which are more flexible in terms of "when and where" - without compromising on quality - to better serve the needs of businesses in the white-collar sector, which represented 18% of our revenue. Today, Elior is at the forefront of this historic transformation of the catering industry.

6 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

Interview with Philippe Guillemot, Chief Executive Officer

What are the key strategic challenges facing Elior in 2020-2021?

The challenge for all of our teams now is to accelerate the execution of the New Elior 2024 plan. Because this will allow us to pull ahead and get back to winning market share when the crisis ends. We've already launched our action plans:

  • In Business & Industry, we've totally recrafted our offering. This is now up and running and is aimed at adapting to new working methods, meeting our guests' new demand for flexibility, and enhancing the nutritional quality of our meals.
  • In the Education market, we're investing in nutrition to make sure everyone can enjoy our healthy, balanced meals. For example, in September 2020 we introduced the Nutri-Score food rating system in our school canteens in France, making us the first - and only - contract caterer to have done so.
  • In Health & Welfare, we have demonstrated the resilience of our services business and have developed ultra-personalized catering solutions focused on individual care, by expanding our home delivery services, for example, and by rolling out senior-specific offerings such as Nutri-Age in Italy and Idequatio in France.

Going forward, we intend to capitalize on our expertise in food safety and hygiene and focus even more on agility and innovation, notably by fast-tracking our digital transformation.

To conclude, given the current health crisis and the lasting effects it will have, what factors are enabling Elior to look to the future with confidence?

We can't deny that the unprecedented global crisis made 2019-2020 a particularly difficult year for the contract catering industry. Although impacted, Elior has demonstrated its resilience, as well as its ability to take the initiative. The business portfolio we have today means that we are less exposed to the impact of the pandemic and the health and safety measures that authorities have put in place to tackle it - lockdowns for example. During this crisis, we have actually been able to further strengthen ties with our clients thanks to strict financial discipline, rigorous management and contract renegotiations, and the truly outstanding commitment of our teams on the ground. By staying firmly on the course we set ourselves when we launched the New Elior strategic plan, we intend to reinforce our differentiating factors in all of our markets, while accelerating our transformation and the rollout of our new offerings in order to emerge more competitive from the crisis and reaffirm our innovation capacity in all of our operations.

UNIVERSAL REGISTRATION DOCUMENT . ELIOR GROUP . 7

  • The Elior Group

Selected Financial Information

1.3 SELECTED FINANCIAL INFORMATION

1.3.1 KEY PERFORMANCE INDICATORS

Organic growth in consolidated revenue: Growth in consolidated revenue expressed as a percentage and adjusted for the impact of (i) changes in exchange rates, using the calculation method described in Chapter 4, Section 4.2 of this Universal Registration Document, (ii) changes in accounting policies, notably the first-timeapplication of IFRS 15 in 2018-2019,and (iii) changes in scope of consolidation.

Revenue retention rate: Percentage of revenue for the previous fiscal year adjusted for the cumulative annual change in revenue from contracts or sites lost since the beginning of the previous fiscal year.

The method applied for calculating this indicator - which is one of the metrics used to analyze organic growth - was revised in 2019-2020 in order to make it more consistent and facilitate comparisons between the Group and its peers.

Adjusted EBITA1: Recurring operating profit including share of profit of equity-accounted investees, adjusted for share-based compensation (stock options and performance shares granted by Group companies) and net amortization of intangible assets recognized on consolidation.

The Group considers that this indicator best reflects the operating performance of its businesses as it includes the depreciation and amortization arising as a result of the capex inherent to its business model. It is also the most commonly used indicator in the industry and therefore enables comparisons between the Group and its peers.

Adjusted EBITA margin: Adjusted EBITA as a percentage of consolidated revenue.

Adjusted earnings per share1: This indicator is calculated based on net profit from continuing operations attributable to owners of the parent, adjusted to exclude

  1. non-recurringincome and expenses, (ii) amortization of intangible assets recognized on consolidation, (iii) exceptional impairment of investments in and loans to non-consolidated companies, and (iv) the impacts of gains or losses on disposals of consolidated companies classified as held for sale. All of these adjustments in (i) to (iv) are net of tax.

Operating free cash flow1: The sum of the following items as defined elsewhere in this Universal Registration Document and recorded either as individual line items or as the sum of several individual line items in the consolidated cash flow statement:

  • EBITDA.
  • Net capital expenditure (i.e. amounts paid as consideration for property, plant and equipment and intangible assets used in operations less the proceeds received from sales of these types of assets).
  • Change in net operating working capital.
  • Other cash movements, which primarily comprise cash outflows related to (i) non-recurring items in the income statement and (ii) provisions recorded for liabilities resulting from fair value adjustments recognized on the acquisition of consolidated companies.

This indicator reflects cash generated by operations and is the indicator used internally for the annual performance appraisals of the Group's managers.

Free cash flow1: The sum of the following items as defined elsewhere in this Universal Registration Document and recorded either as individual line items or as the sum of several individual line items in the consolidated cash flow statement:

  • Operating free cash flow, as defined above.
  • These indicators are not measurements of financial performance under IFRS and should not be considered as alternatives to other indicators of the Group's operating performance, cash flows or any other measure of performance used in accordance with IFRS. These indicators as presented in this Universal Registration Document are for information purposes only and may differ from and may not be comparable to similarly titled measures used by other companies. Their calculations are based on various assumptions. These amounts have not been, and, in certain cases, cannot be, audited, reviewed or verified by an independent auditor. The information provided is inherently subject to risks and uncertainties and may not give an accurate or complete picture of the financial position and/or results of operations of acquired businesses. The Group presents these indicators because it believes they are helpful to readers of this document for understanding its operating performance. They have limitations as analytical tools and should not be considered as a substitute for an analysis of the Group's operating results as reported under IFRS.

8 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

Selected Financial Information

  • Tax paid, which notably includes corporate income tax, the CVAE tax in France the IRAP tax in Italy and State Tax in the United States.

Leverage ratio1: The ratio between (i) the Group's net debt (at the given period-end determined based on the definition and covenants in the Senior Facilities Agreement as described in Chapter 4, Section 4.8.2 of this Universal Registration Document: "Senior Facilities Agreement", i.e. excluding unamortized issuance costs

and the fair value of derivative instruments) and (ii) adjusted EBITDA (EBITA adjusted to exclude the impact of stock option and performance share plans and depreciation and amortization) calculated on a rolling basis for the twelve months preceding the period-end concerned, further adjusted to exclude the impacts of acquisitions and divestments of consolidated companies during the twelve months preceding said period-end.

1.3.2 KEY FIGURES

€3,967 MILLION

IN CONSOLIDATED REVENUE

€1,778 MILLION

€2,182 MILLION

GENERATED BY CONTRACT CATERING &

GENERATED BY CONTRACT CATERING &

SERVICES - FRANCE

SERVICES - INTERNATIONAL

22,700

4 MILLION CUSTOMERS EACH DAY

RESTAURANTS AND POINTS OF SALE

105,000 EMPLOYEES

OPERATIONS IN 6 COUNTRIES

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 9

  • The Elior Group

Selected Financial Information

Income Statement Data

(in € millions)

Year ended September 30

2020

2019

Revenue from continuing operations

3,967

4,923

Contract Catering & Services

3,960

4,901

- France

1,778

2,212

- International

2,182

2,689

Corporate & Other

7

22

Revenue growth1

(19.4)%

0.8%

Organic revenue growth2

(19.7)%

(0.8)%

Recurring operating profit/(loss) from continuing operations

(86)

160

Recurring operating profit margin from continuing operations3

(2.2)%

3.3%

Net profit/(loss) from continuing operations attributable to owners of the

(446)

68

parent

Adjusted attributable net profit/(loss) for the period

(222)

101

Adjusted earnings per share (in €)4

(1.28)

0.57

Dividend (in €)

-

0.29

  1. Revenue growth corresponds to the percentage increase in the Group's consolidated revenue for a given accounting period versus the comparative period of the previous fiscal year.
  2. See definition in Chapter 4, Section 4.2 of this Universal Registration Document.
  3. Recurring operating profit margin from continuing operations corresponds to recurring operating profit/(loss) from continuing operations as a percentage of revenue.
  4. See definition in Section 1.3.1 above.

Balance Sheet Data

(in € millions)

At September 30

2020

2019

Goodwill

1,719

1,851

41

Cash and cash equivalents

83

Equity

1,132

1,670

Gross debt

1,033

618

Net debt1

767

539

NA2

1.80

1

Leverage ratio (net debt /adjusted EBITDA)

  1. Based on the definition and covenants in the Senior Facilities Agreement, as described in Chapter 4, Section 4.8.2, "Senior Facilities Agreement" of this Universal Registration Document, i.e. excluding unamortized issuance costs and the fair value of derivative instruments.
  2. Not applicable in view of the covenant holiday obtained until September 30, 2022.

10 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

Selected Financial Information

Cash Flow Statement Data

(in € millions)

Year ended September 30

2020

2019

EBITDA1

111

303

Net capital expenditure2

(89)

(114)

Change in operating working capital3

(9)

84

Other cash movements

(17)

(23)

OPERATING FREE CASH-FLOW4

(4)

251

Tax paid

(11)

(24)

FREE CASH FLOW5

(15)

227

  1. (2) (3) (4) (5) See definitions in Section 1.3.1 above.
  2. Net capital expenditure corresponds to amounts paid as consideration for property, plant and equipment and intangible assets used by contract catering and services operations as well as by support and corporate activities, less the proceeds received from sales of these types of assets. This net amount represents the sum of the following items as presented in the consolidated cash flow statement:
    Purchases of property, plant and equipment and intangible assets.
    Proceeds from sale of property, plant and equipment and intangible assets.
  3. Change in operating working capital corresponds to the net change during the period in the cash required for maintaining current assets and liabilities that are used by contract catering and services operations as well as by support and corporate functions. This cash flow is presented in the consolidated cash flow statement and covers the following current assets and liabilities:
    Inventories and work-in-progress. Trade receivables.
    Trade payables.
    Employee-related payables and receivables, including accrued income related to the CICE tax credit in France. Tax receivables and payables (excluding corporate income tax, deferred taxes and the CVAE and IRAP taxes)

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 11

  • The Elior Group

Information about the Group

1.4 INFORMATION ABOUT THE GROUP

Company Name

Elior Group

Registration Particulars and Legal Entity Identifier

The Company is registered with the Nanterre Companies Registry under number 408 168 003. Its legal entity identifier (LEI) is 969500LYSYS0E800SQ95.

Date of Incorporation and Term

The Company was incorporated on July 8, 1996 for a term of ninety-nine years from the date of its registration with the Companies Registry, expiring on July 8, 2095 unless said term is extended or the Company is wound up in advance.

Registered Office, Legal Form and Governing Law

The Company's registered office is located at 9-11 allée de l'Arche, 92032 Paris La Défense, France. The telephone number of the registered office is +33 1 71 06 70 00. Elior Group is a French joint-stock corporation (société anonyme) with a Board of Directors, and is governed by the laws and regulations applicable in France (notably Book II and Chapter X of the French Commercial Code) as well as the Company's bylaws (hereinafter the "Bylaws").

Website

The Company's website address is www.eliorgroup.com. Other than information specifically incorporated by reference, any information available on the website that is referred to in this Universal Registration Document via hypertext links (www.eliorgroup.com) does not form part of this Universal Registration Document. Consequently, such information has not been either reviewed or approved by the AMF.

History and Development of the Group

Since it was founded in 1991, the Group has grown from a contract caterer with operations only in France to an international group with two core businesses: contract catering and services. It currently operates in six countries.

The Group was co-founded by Francis Markus and Robert Zolade who, together with 300 managers, acquired a 35% stake in Générale de Restauration, the contract catering subsidiary of the Accor group.

In 1993, the Group entered the French concession catering market and became the market leader in 1997. In 1998 it adopted the name "Elior", and in 1999 began accelerating its development in the European contract catering market through acquisitions in the United Kingdom, Spain and Italy.

In 2000, the Company was listed on the Premier Marché of Euronext Paris and shortly afterwards the Group expanded its concession catering business in Spain and Italy through partnerships with MyChef and Areas, and built up its presence in contract catering in Spain through an alliance with Serunion. The Group further diversified its business by entering the services industry in France in 2004 through the acquisition of Hôpital Service, a company that provides services for healthcare establishments (specialized cleaning and hospitality).

In 2006, the Company delisted from Euronext and was taken private by Charterhouse, Chequers and Robert Zolade.

As from the beginning of 2010 the Group engaged in a number of acquisitions in various markets and businesses, beginning in that year with Copra, an Italian contract caterer, as well as Sin&Stes, one of France's leading corporate cleaning services firms, which pushed it up to the position of sixth-largest contract cleaning company in France. In 2011, the Group expanded its contract catering business in Spain by acquiring the Alessa Catering group. In early 2012, the Group consolidated its operations under the "Elior" brand name, which also became its trade name in France, the United Kingdom and Italy. Also in 2012, it acquired two contract catering companies: Gemeaz in Italy (which made it the country's leading contract caterer), and Ansamble in France (which placed it as France's joint leader in the contract catering market). In 2013, the Group entered the US contract catering market by acquiring TrustHouse Services (since renamed Elior North America), a leading player in the education and healthcare sectors in the United States. In October 2014, the Group acquired Lexington, a UK-based contract caterer specialized in high-end catering services in the City of London.

On June 11, 2014, the Company was relisted on the Premier Marché of Euronext Paris.

In 2015, the Group reinforced its position as a global player in the concession catering market by raising its stake in Areas to 100%. It also increased its contract catering presence in the United States by acquiring Starr

12 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

Information about the Group

Catering Group (since renamed Constellation Culinary Group), a US market leader that offers a full range of premium catering services.

In 2016, THS took on the Group's flagship contract catering brand name, becoming Elior North America. During that year, Elior North America acquired ABL Management, which operates in the university and corrections segments, and Preferred Meals (specialized in contract catering and home deliveries in the education and seniors markets). In the United Kingdom, Elior acquired Waterfall Catering Group, which operates in the growth markets of education and healthcare, and as a result became the UK's fourth-largest contract caterer. The Group also made its entry into Asia in 2016, by simultaneously acquiring two contract caterers in India: MegaBite Food Services and CRCL. Through these two acquisitions, Elior India is now one of the top three players in the Indian contract catering market.

In 2017, the Group pursued the expansion of its contract catering activities in the United States by successively acquiring CBM Managed Services, Lancer Hospitality, Abigail Kirsch, Corporate Chefs, Design Cuisine and Sidekim. The acquisition of Corporate Chefs strengthened Elior North America's positions in the premium corporate catering market and the education sector. Lancer Hospitality provides professional food management services in a variety of settings including cultural venues, leisure attractions, business centers, schools and healthcare facilities. As it is based in Minnesota, the

acquisition of Lancer Hospitality enabled the Group to broaden its presence in the US.

In 2018, the Group acquired a new company in the United States - Bateman Community Living - reinforcing Elior North America's position in the seniors catering sector. In total, the Group has carried out 19 acquisitions in the United States in the space of three years.

In 2019, having reviewed the strategic options for its concession catering business, Elior Group sold its subsidiary Areas, opening up a new chapter in its history by refocusing on its long-standing businesses of contract catering and services. At the same time, the Group launched its New Elior strategic plan, which sets out its roadmap up until 2024.

Also in 2019, Elior reinforced its leading position in senior nutrition and community meals in the United States, by creating TRIO Community Meals, bringing together three regional brands.

In the United Kingdom in 2019, then in the United States in 2020, Elior launched Lexington Independents to create a single brand to the serve independent schools. This new brand has strengthened the Group's presence in the private education market, offering bespoke catering solutions for both pupils and teachers.

For the year ended September 30, 2020, the Group's revenue amounted to €3.967 billion.

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  • The Elior Group

Organizational Structure

1.5 ORGANIZATIONAL STRUCTURE

The simplified organization chart below presents the Group's legal organizational structure at December 31, 20201.

BIM

EMESA

FSP

20.01%

7.66%

5.20%

67.13%

FREE FLOAT

100%

BERCY PARTICIPATIONS SAS

ELIOR GROUP (SA)

TREASURY SHARES

100%

non-material

ELIOR PARTICIPATIONS

(SCA)

99.99%

100%

ELIOR RESTAURATION &

RESTAURANTS ET SITES

Subsidiarie

(SAS)

SERVICES (SA)

s

City Sites

France

100%

ELIOR ENTREPRISES (SAS)

ARPEGE (SAS) and

Subsidiarie

othersubsidiaries

s

99.86%

ELRES (SAS)

Subsidiarie

s

99.95%

L'ALSACIENNE DE

RESTAURATION (SAS)

100%

ELIOR SERVICES

PROPRETE ET SANTE (SAS)

100%

ANSAMBLE (SAS)

100%

100%

Othersubsidiaries

Italy

India

99%

ELIOR RISTORAZIONE

Subsidiarie

ELIOR INDIA FOOD

(SPA)

s

SERVICES (LLP)

Spain

Subsidiarie

100%

SERUNION (SAU)

s

Othersubsidiaries

United Kingdom

88.4%

Subsidiaries

ELIOR UK HOLDINGS

including

LEXINGTON

(LTD)

and

WATERFALL

United States

92%

GOURMET ACQUISITION

Subsidiarie

HOLDING (INC)

s

  • The percentage ownership figures stated in this organization chart correspond to the percentage of voting rights held in the Company's direct and indirect subsidiaries.
    See the list of consolidated companies in Note 12 to the consolidated financial statements (Chapter 4, Section 4.10).

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The Elior Group 1

Organizational Structure

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  • The Elior Group

The Group's Business Model

1.6 THE GROUP'S BUSINESS MODEL

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The Elior Group 1

The Group's Business Model

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 17

  • The Elior Group

The Group's Businesses and Strategies

1.7 THE GROUP'S BUSINESSES AND STRATEGIES

1.7.1 BUSINESSES

The Group is an international player in contract catering

  • services, serving 4 million customers every day at approximately 22,700 restaurants and points of sale across the world, and looking after 2,300 sites for clients in France through its services offerings. It has over 105,000 employees based in 6 main countries, in Europe, North America and Asia.

The Group's contract catering business serves three key client markets: corporate entities and government agencies (Business & Industry), educational establishments (Education), and health and welfare establishments (Health & Welfare). It operates its contract catering activities in its traditional markets of France, Spain, Italy and the United Kingdom as well as in the United States since 2013 and India since 2016.

Based on revenue generated in fiscal 2019-2020, the Group estimates that it is the second-largest pure player in contract catering & services.

The majority of the Group's services business is conducted in France and involves the provision of soft facility management solutions, notably cleaning, reception, concierge, light maintenance and grounds maintenance services. Through this business, the Group provides public and private-sector institutional clients with a wide array of outsourced solutions ranging from cleaning and reception services through to the management of offices, hotels, shopping malls, leisure and vacation parks and office and apartment buildings. The Group estimates that it is the sixth-leading cleaning services provider in France and the number one provider of outsourced cleaning and hospitality services for the French healthcare sector.

In the year ended September 30, 2020, the Group generated total consolidated revenue of €3,967 million and its adjusted EBITA was a negative €69 million.

1.7.1.1 Contract Catering

2019-2020 key figures:

  • An operating presence in six main countries: France, Italy, Spain, the United Kingdom, the United States and India
  • 22,700 restaurants and points of sale in six main countries
  • 4 million guests per day
  • 85,000 employees worldwide

The Group's contract catering business addresses three different client markets: Business & Industry (companies and government agencies), Education (private and public educational establishments, from nurseries to higher- education), and Health & Welfare (private, public and not- for-profit healthcare providers and the operators of care homes and welfare establishments). The Group serves all three of these markets in each of the countries in which it has contract catering operations.

Through this business, the Group offers dining services, meal deliveries, vending solutions and foodservices technical support.

1.7.1.1.1 The Business & Industry market

2019-2020 key figures:

  • €1,620 million in revenue (41% of total consolidated revenue)
  • 5,600 restaurants
  • 1.2 million guests per day

The Business & Industry market comprises private sector clients in the manufacturing and tertiary industries, including leisure and transport, as well as institutions such as public-sector companies, government agencies, cultural organizations, military bases and corrections facilities. The Group's expertise now also enables it to offer catering services to small and mid-sized enterprises (SMEs), thanks to the development of dedicated technological solutions (mobile apps, smart fridges, etc.).

The Group proposes varied offerings that are specifically targeted to its different market segments and it constantly innovates to create catering solutions that meet the changing needs and expectations of its guests. The ways it achieves these aims include taking inspiration from commercial catering, digitizing certain services and broadening its offerings (in terms of serving times, venues, menus, recipes, etc.).

18 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

1.7.1.1.2 The Education market

2019-2020 key figures:

  • €1,149 million in revenue (29% of total consolidated revenue)
  • 14,100 school restaurants
  • 2.1 million children and students catered for each day in Europe and the United States

Clients in the Education market include public and private education institutions covering a broad spectrum of ages, ranging from pre-schoolday-care centers and elementary and secondary schools through to universities and other higher education institutions.

School catering is one of the Group's long-standing markets. Thanks to its network of central kitchens in Europe and the United States, combined with its knowhow in managing small sites, and its expertise in food hygiene, safety and traceability, it enjoys a solid leadership position in both the public and private education sector in Europe.

With over 120 central kitchens in France, Spain and Italy, the Group has the largest central kitchen infrastructure in Europe, with a regional network that enables it to combine high productivity with a local presence. It has similar infrastructure in the United States and India, giving it a strong platform for consolidating its leadership in those countries.

Keenly aware of the role it has to play in educating tastes and encouraging healthy eating, the Group pays particular attention to the flavor of the food it serves, as well as to using local and certified food and "homemade" recipes. It also takes care to pass on the message to its young guests about the importance of taking pleasure in eating well.

One of the main challenges in the Education market for Elior, like other caterers, is to demonstrate the quality of its services and make market players aware that quality has a price tag.

1.7.1.1.3 The Health & Welfare market

2019-2020 key figures:

  • €1,198 million in revenue (30% of total consolidated revenue)
  • 3,000 restaurants
  • 570,000 guests per day

The Elior Group 1

The Group's Businesses and Strategies

The Group's main clients in the Health & Welfare market are hospitals, clinics, retirement homes, residential homes and day-care centers for disabled, elderly and dependent people, and non-profit organizations that provide community meal services. Whatever the venue, meals form part of the overall care process in this market, and a good diet contributes to the recovery of patients and the well-being of care home residents.

The Group designs catering offerings for health and welfare establishments that combine nutrition with the enjoyment of eating. In the hospital segment, catering solutions are tailored to each patient's pathology, and the new generation of cafeterias add to the well-being of both staff and visitors. For seniors, the Group draws on its expertise in food hygiene and safety, and has a strong focus on innovation. It specializes in specifically adapted textures and nutrient-rich food for seniors, and has developed solutions for delivering meals to people at home and in congregate settings.

The Group's teams also offer support to clients that are adapting their business models to the increase in outpatient surgery, by providing new services for patients from before they are hospitalized until they go home, including a specially-adapted type of on-site catering.

1.7.1.1.4 Contract catering brands

The Group operates in the contract catering market through several different brands and trade names, which vary depending on the sector, client or country concerned.

France

  • Elior
  • Arpège
  • Ansamble
  • L'Alsacienne de Restauration

Spain

  • Serunion
  • Alessa
  • Arce
  • Arume
  • Hostesa
  • Ullasar
  • Singularis

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  • The Elior Group

The Group's Businesses and Strategies

India

  • Elior
  • CRCL
  • Megabite

Italy

  • Elior
  • Elior Servizi
  • Gemeaz
  • Hospes

United Kingdom

  • Elior
  • Caterplus
  • Edwards & Blake
  • Lexington
  • Taylor Shaw

United States

  • Abigail Kirsch
  • Aladdin
  • A'viands
  • Constellation Culinary Group
  • Corporate Chefs
  • Cura
  • Design Cuisine
  • Lancer Hospitality
  • Lexington Independents
  • Preferred Meals
  • Summit
  • Traditions
  • TRIO Community Meals

1.7.1.2 Services

2019-2020 key figures:

  • No.1 for cleaning and hospitality services for the French healthcare sector
  • 2,300 sites
  • 20,000 employees

Elior Services is a French brand and has three main areas of expertise: cleaning and hospitality services in clinics, hospitals and specialized healthcare establishments; cleaning and hygiene services in offices and industrial premises (including in highly sensitive locations such as white rooms); and facility management (which includes reception, concierge, mail handling and grounds maintenance services).

In the healthcare sector - which has been Elior Services' principal market since the outset and where it is the leader in France - the company offers a wide range of solutions including specialist cleaning services, laundry services, in- room meal services and hospitality services. One of the keys to its success in this sector is its continuous innovation approach.

Elior Services also meets the requirements of a wide range of clients in other sectors including large corporations, high-end hotels, leisure venues (stadiums, museums, movie theaters etc.), schools and sensitive industrial sites, as well as shopping malls, where cleanliness and services are essential for brand image.

Elior Services proposes value-added solutions to help its clients create pleasant working environments. Its corporate concierge services are also proving increasingly popular with companies looking to offer that little extra to attract and retain talent.

Thanks to Elior Services' in-depth expertise in hygiene and disinfection, it was able to expand its offerings in order to swiftly offer responses to the challenges caused by the Covid-19 crisis.

1.7.1.3 Market trends

The Elior group - a worldwide player in contract catering and services - develops and provides catering and services solutions in three key markets - business & industry, education and health & welfare. Since March 2020, the Covid-19 crisis has highlighted two of the fundamentals underlying the Group's business in these three markets:

  • First and foremost, food safety, hygiene and traceability in all of the Group's restaurants. Food safety and hygiene are imperative in the contract catering business and involve a range of different issues, including strictly selecting and monitoring suppliers, managing food safety alerts, and drawing up food safety and hygiene standards. In addition to the strict measures it takes to ensure the quality of the meals it serves, Elior has reinforced its usual health and safety standards in light of the current public health emergency.
  • The essential role that Elior plays in society by offering healthy, balanced and affordable meals to as many people as possible - both at school and at work. The economic and social situations that have been exposed since the outbreak of Covid-19 have highlighted food inequality. For example, in many areas, the national lockdowns and school closures during the crisis deprived many children of their one full meal of the day.

20 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

The Group's Businesses and Strategies

In order to retain its market-leading positions, the Group ensures that it responds to society's new main trends and developments. The outbreak of Covid-19 has accelerated the long-term trends the Group has observed over the past few years. The impact this crisis has had on our various markets - starting with business & industry - has reinforced the need to add even more value to our offerings so they correspond closely to today's new eating habits and meet consumers' high expectations in terms of food quality. Our priority is therefore to step up the pace of the projects in our strategic plan, for all of our operations, with the overall aims of guaranteeing our guests' well-being and respecting the environment, while providing delicious, high-quality food and relaxed and friendly dining experiences.

1.7.1.3.1 Ensuring the well-being of our clients and guests

a) Guaranteeing health and safety

The health and safety of our guests is the number one priority for our teams. The certifications obtained and measures put in place by the Group during the Covid-19 crisis have underscored our expertise in hygiene and safety and our constant quest to progress even further in these areas.

In France, Elior drew up a specific Covid-19 prevention guide in collaboration with Doctor François-Henri Bolnot, who is a veterinary doctor, a doctor in microbiology and a professor of food safety. The content of this guide was also approved by the Group's occupational physician. On their gradual reopening, the Group's restaurants in the business & industry market were audited by external state-recognized laboratories in order to assure the independence of their findings. These audits particularly checked that the restaurants were respecting the following: (i) specific Covid-19 cleaning and disinfection procedures, (ii) the instructions for dining room organization and guest reception (plexiglass screens, guest circulation flows, socially distanced tables, removal of self-service condiments), (iii) the rules on communicating Covid-19 measures to guests, and (iv) the requirement for staff to wear personal protective equipment.

In Spain, Serunion was the first Spanish contract caterer to be certified by AENOR (a leading Spanish standards and certification agency) for its safety and hygiene measures put in place during the Covid-19 crisis.

Proposing catering offerings during a public health emergency sometimes also means that new catering concepts need to be invented. For instance, in the United States, we launched a concept called Safe Café, which ensures customers' health and safety, in line with public health guidelines. When customers see the Safe Café logo they know that the restaurant staff respect stringent health and safety rules.

Care is also a central focus for Elior Services, which is a benchmark player in France for cleaning services, hospitality services in the healthcare sector and facility management. This is clearly reflected in the company's corporate slogan - "Taking care of your environments and the people in them".

As soon as France's first national lockdown was announced, Elior Services moved into action to design bespoke, easy-to-use disinfection offerings for business & industry clients to use when offices were allowed to open again. These clients have had to put in place exceptionally rigorous measures to provide the safest possible working environments and health and safety conditions for their employees. Elior Services' offerings cover two different types of services: traditional disinfection using a manual process or deep disinfection using a spray technique.

b) Catering for different nutritional needs

Proposing healthy meals to everyone is in our DNA and we play a pioneering role in helping improve overall eating habits. Because we believe that taking care of our guests starts with the food we serve them, we work with our more than 600 expert dietitians and nutritionists to create healthy, balanced menus that respect the main recommendations issued by the public health authorities.

In France, Elior was the first contract caterer to use the Nutri-Score food coding system in its school canteens and corporate restaurants. Designed by the French National Public Health Agency based on research carried out by the team headed by Professor Serge Hercberg (President of the French National Nutrition and Health Program, the PNNS), Nutri-Score provides clear, simple and understandable nutritional information about the dishes the Group proposes and meets the increasing demand from consumers to have the nutritional information they need to make the best food choices. After trialing the system in our corporate restaurants in the fall of 2019, we decided to gradually roll it out as from September 2020 to all of our school canteens. This objective to inform children and their parents about the nutritional values of the meals we offer confirms our pioneering position in educating people about healthy, great tasting food.

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  • The Elior Group

The Group's Businesses and Strategies

Taking care of our guests also means factoring in their specific needs and expectations. We need to make sure that each of our guests can have great-tasting food options that take into account any food intolerances they may have or their moral or religious beliefs. For example, we propose high-quality options for guests who want to reduce their intake of animal proteins. Vegetarian offerings are now available in our corporate restaurants and school canteens, and our specialist teams make sure that the plant-based alternatives we propose provide the best nutritional balance for all ages. The Group intends to increase its proportion of vegetarian recipes by encouraging the sharing of best practices and creativity between its chefs around the whole world via a digital platform.

Another illustration of our nutritional expertise and adaptability is the food services we provide to professional cyclists. Throughout the 2020 sporting season, our chefs catered for the 25 racers in the Total Direct Energie cycling team, and they will be doing the same during the 2021 season. These professional competitors can count on Elior's nutritional and culinary know-how to help them push their performance in each race. Providing healthy food adapted to the specific needs of top-level sport is a challenge in itself and the partnership clearly highlights Elior's best-in-class expertise in food and nutrition.

The pleasure of eating also plays a central role in hospitals and retirement homes, as it is a key factor for the well- being of patients and residents. In all of our host countries, we design menus that are adapted to the different pathologies of our guests in the healthcare and seniors markets. We are real specialists in this domain and our offerings include recipes designed specifically for people who have difficulties with chewing and swallowing. We also offer specially-textured food to help patients, seniors and people with disabilities rediscover the pleasure of eating.

Aware of the need to adapt food services for seniors to their changing needs and increasing dependence as they grow older, in France, Elior created the Idequatio concept in 2019-2020. The underlying aim is to help people continue to enjoy eating and to eat unaided for as long as possible, whatever their state of health. This innovative culinary offering is adapted on a case-by-case basis to the health and tastes of each elderly dependent person in order to make it easier for them to eat, facilitate their medical care and contribute to their everyday well-being. Thanks to this concept we can help guests enjoy their food, in total safety, and ease the daily work of care workers.

In care homes in Spain, Serunion likewise works constantly on improving residents' well-being. One of its recent projects involved carrying out studies in four care homes on whetting appetite through smell. The findings showed that sense of smell is an extremely important factor in stimulating elderly people's appetite and therefore plays a key role in their overall dining experience. Consequently, Serunion's catering offerings for care homes now include the possibility of aromatherapy for appetite stimulation.

In the United Kingdom, Elior UK has developed a training program for its chefs called Dining with Dignity, which helps them make texture modified food appetizing. Many elderly people suffer from problems with chewing and swallowing that increase with age, as well as losing their independence, all of which lead to risks of malnutrition. To counter these problems, for elderly guests Elior's teams propose food and beverages with specially modified textures and which look appetizing. This program represents an ambitious training path for Elior UK's chefs, strengthening their expertise in preparing and serving menus suited to the needs of guests suffering from dysphagia. It is thanks to this type of initiative - which contributes to our high-quality catering offerings - that we are able to improve the quality of life of residents in retirement homes and care homes.

c) Taking care of vulnerable people

The social and economic context experienced since the outbreak of Covid-19 has underlined the essential role that contract catering plays in all of the Group's host countries. Contract caterers are fundamental to society, offering healthy, balanced and affordable meals to many people, both at school and at work.

In the United States, Elior North America's teams have been mobilized during the crisis to continue to provide community catering services to the most vulnerable members of society. In all, between March and September 2020 the company delivered 51.6 million meals to elderly people, students and other people particularly affected by the crisis. Our teams tirelessly supported these communities, both physically and psychologically, and will continue to do so.

22 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

The Elior Group 1

The Group's Businesses and Strategies

In Spain, Serunion played its part in the combat against food insecurity by catering for 18,000 Andalusian pupils receiving free school meals throughout the lockdown.

Elior Services also takes care of people in healthcare establishments, offering its expertise in managing health risks and healthcare hospitality. Hospital and operating rooms are kept spotlessly clean thanks to specialist cleaning and disinfection protocols adapted to each particular space. And hospitality services - comprising reception and other welcome services as well as meal and snack services - add to patients' comfort and well-being.

At the regional hospital complex in Mulhouse - where one of the first cases of a Covid-19 cluster broke out in France

  • Elior Services' teams were mobilized day and night during the crisis. Elior Services provides specialist cleaning services for the 120,000 sq.m. that make up this hospital complex, and 130 employees worked on cleaning the entire space, including technical facilities, medical imaging equipment, maternity wards and dialysis units.

The Group has put in place numerous initiatives to meet guests' special nutritional and dietary requirements in healthcare establishments and residential homes for seniors. Our innovative food offerings are tailored to the health and tastes of each person with a view to making it easier for them to eat, facilitating their medical care and contributing to their everyday well-being.

In France, our catering and services teams worked together in 2019-2020 on the renewal of our contract with the Fondation Pauliani retirement and care home for a further five years, with the Group offering many solutions to improve the quality of life of the home's 214 residents. These include the Bouchées Saveurs concept (bite-sized portions for people suffering from Alzheimer's) and the innovative culinary offering, Idéquatio, which is specifically suited to dependent elderly people. Regional dishes will also be introduced into the overall food offering to give the home a more personalized culinary identity. And lastly, the renewed contract comprises many socially responsible measures, including "eco-friendly disinfection" (using water to clean the floors) and a range of eco-certified and eco-friendly products, as well as helping the home with managing its waste-sorting system.

1.7.1.3.2 Respecting the environment and

people

a) Taking care of the planet

Because we believe we can only really take care of our guests if we look after the planet, we take action on a daily basis to limit the impact of our business on the environment. The ways we do this include using sustainable ingredients, taking steps to avoid plastic

pollution and implementing initiatives to reduce food waste - all of which are priority areas in the Group's CSR strategy: the Elior Group Positive Foodprint Plan™.

Choosing great-tasting, healthy and sustainable ingredients is of utmost importance to Elior. In order to select the best ingredients, we use premium suppliers and favor local sourcing and seasonal, certified produce. Our teams at the Orange Cesson-Sévigné restaurant in Rennes won the sustainable nutrition prize awarded in March 2020 by Bleu Blanc Coeur - a non-profit organization that campaigns for good diets for animals in order to improve the nutritional quality of food. This prize rewards the commitment of both Elior and its client, Orange, to promoting healthy, environmentally-friendly cooking.

In the United Kingdom, 86.1% of the fish served in Elior UK's restaurants is sustainably sourced, helping protect our seas and oceans over the long term.

In France, Elior has teamed up with the Association d'Organisations de Producteurs Pêches et Abricots de France to offer guests seasonal peaches and apricots that carry the Vergers Ecoresponsable label, certifying that they are grown using production methods that respect the environment. This approach is fully in line with the Group's pledge to develop healthy, balanced, and environmentally-friendly food offerings.

In the Business & Industry market in France, our teams are working on eliminating single-use plastic products that are not recyclable and not recycled in our restaurants. Reducing the use of these products is essential to limit the ecological damage that they cause over the long term. We now offer our clients packaging solutions made from organically-sourced,bio-degradable - and therefore more sustainable - materials, such as wood, cardboard, bagasse (sugarcane pulp), PLA (a plant-based plastic) and polyethylene terephthalate (PET - a highly recyclable plastic resin).

In the Education market, our French teams offer clients ways of making school canteens more environmentally friendly, especially in terms of reducing food waste and general waste. Eight practical measures have been developed with the help of dieticians, nutritionists, CSR managers and developers. Three municipalities - Lognes, Sedan and Mandelieu - agreed to act as pilots for testing these initiatives over a period of two to three months in 2019-2020 and the results were encouraging as there was a 27% reduction in leftovers.

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  • The Elior Group

The Group's Businesses and Strategies

In the United Kingdom, Lexington has launched an anti- food waste program called TRASHED to promote recipes utilizing food that is underused and generally ends up being thrown away, such as vegetable juice, stalks and leaves, stale bread, overly ripe fruit and cheese rind. As soon as they were created, the TRASHED recipes were heavily promoted to Elior UK's suppliers, clients, guests and teams, and the client sites that have adopted the program in recent months have seen a significant reduction in waste.

The fight against food waste is a priority action area for Elior and our aim is to get people thinking about it from a very early age. In France, we have teamed up with the start- up, Expliceat, to propose anti-waste workshops and training in school canteens, company restaurants and health and welfare establishments. As part of this joint effort, Elior and Expliceat are raising awareness about fighting food waste through cookery workshops creating recipes using uneaten bread, fruit and vegetables.

Another major challenge for future generations is preserving biodiversity. In 2019-2020, our Spanish subsidiary took part in the Fish4Kids project to promote sustainable fish consumption. Held in 30 schools in Spain, Fish4Kids is about organizing games and fun activities to improve children's knowledge about marine biodiversity and protecting marine animals and fish stocks.

b) Supporting local communities

When we select the producers we work with, we place particular importance on the human relations we have with them and favor those with strong local connections.

In 2013, Elior France set up a policy for purchasing regional products that respect strict specifications. Called "Selected Products", these give guests a real taste of France's regions while also raising their awareness about sustainably sourced food that respects nature and people. Despite the difficult economic context prevailing since the outbreak of Covid-19, Elior decided to maintain the awareness-raising events relating to these products in its restaurants, such as proposing French-grown strawberries in the spring of 2020.

We also contribute to environmental initiatives through Elior Group Solidarités - Elior's non-profit organization that supports community-based events and ventures in France and internationally. The organizations supported by Elior Group Solidarités include the Association Française d'Agroforesterie and the Centre de Développement de l'Agroécologie, which seek to protect biodiversity in their regions by promoting agroecology. Both of these organizations work on a regional scale, helping farmers and breeders to change their production and breeding methods. Elior's long-term goal is to be able

to offer local and responsible products originating from these projects in the Group's school canteens located in the regions where the organizations work. In so doing we will be able to increase our proportion of local supplies and raise guests' awareness about environmental issues, while at the same time showcasing sustainable farming practices and forging links with local farms.

c) Supporting and valuing our people

Helping our 105,000 employees build their careers and realize their full potential is one of the main pillars of the Group's CSR strategy.

With this in mind we have adopted an ambitious policy aimed at ensuring our people have the best possible opportunities to develop their skills at every stage of their career. This involves risk prevention, setting objectives, internal promotion, access to training and many other aspects. And as a responsible and committed employer, we believe our teams should reflect the diverse society we live in.

One example of the way we help our employees build their careers is through Elior Services University. Designed for service operatives and team leaders, whatever their level of studies, this facility offers employees the possibility of moving up the career ladder through two training programs: "Team Leader" and "Site Manager". Following a final exam, graduates of the programs receive a professional qualification certificate. Elior Services undertakes to offer these graduates a job matching the level of their new qualification within twelve months of receiving their diploma. Each year, 150 operatives apply to become managers and are given training by the Elior Services University to prepare them for their future responsibilities. A wide range of skills are taught, including Client Relations, People Management, Quality, Health & Safety, Sustainable Development, and Business Management.

1.7.1.3.3 Offering delicious meals and moments to savor

a) High-quality ingredients

As a caterer, if we want our guests to enjoy the food we offer, we have to give them high-quality cooking with all the flavors of high-quality ingredients.

Cooking has always been at the heart of Elior's business. In all of the regions where it operates the Group hires chefs and regularly trains them in both traditional and innovative culinary techniques. And wherever they are based, our chefs work with nutritionists to devise recipes that are both tasty and nutritional. For example, in Italy the Group has a Food Academy, which is used as a testing and development center, where chefs and nutritionists

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share best practices and new recipes as well as carrying out research work. It is a place where our Italian chefs can hone their skills and come up with the best food preparation and cooking techniques to create delicious, balanced recipes. In France, the Group has a food innovation center called the LAB, where new ideas can be tried out to respond to the latest consumer trends and create new offerings.

To offer our guests the very best and stay one ahead of the curve, we apply a highly innovative culinary approach. This approach is the fruit of the know-how of our chefs, who are driven by a desire to excel and who get inspiration by exchanging ideas with colleagues from all of our host countries. In 2019-2020, an event based on vegetarian cuisine was organized for Elior chefs of six different nationalities to come together and share best practices, recipes and new culinary techniques. The overall aim of the event was for French, British, Spanish, Italian and American chefs to find out more about Indian vegetarian cooking.

In addition, every year the Group holds an international chefs competition, where a dozen chefs from six different countries compete against each other in teams. This is an ideal opportunity for the competing chefs to share their food culture and passion for cooking.

Culinary innovation is also the idea behind the partnerships the Group has developed with incubators such as Reimagine Food, SmartFood Paris and United Kitchens, which help us find and support technological and food-related innovations or ideas for new solutions or markets.

b) Friendly, relaxed settings

An enjoyable dining experience is not just about what's on our plate - it's also about the atmosphere of the place we dine in. That is why we always strive to make our restaurants ever more friendly, comfortable and relaxing spaces by continually developing new designs and concepts. In the Business & Industry market, the quality of the corporate catering offer is a sign of how employers value their staff. So it's not just a question of feeding guests but of making sure that meal times are moments to enjoy and savor.

Today's corporate catering concepts equally need to be geared to new work organization methods. In the current era of coworking, dining areas tend to also be used as meeting spaces at any point in the day. Our guests like areas that can be adapted to their pace of work and life in general, and which meet a range of diverse needs. Elior has responded to these changing trends by introducing new concepts and solutions, such as more collaborative

spaces, with longer opening hours, which propose customized offerings from breakfast through to dinner.

The Group's expertise in this domain goes beyond dining areas. For instance, thanks to its highly professional hospitality services, Elior Services contributes to the brand image of many high-end hotels in France.

In order to help its clients return to the best possible working conditions following the national lockdown in France in March and April 2020, Elior Services offered to partner them with re-opening their sites, both in terms of cleaning their premises, and putting in place the necessary configurations for social distancing. As part of this support, Elior Services offered goods and equipment handling, plumbing and locksmith services, as well as all of the assistance needed for adapting work environments to make them Covid-19 safe, such as reorganizing work spaces and installing floor markings, plexiglass screens and hand sanitizer stations.

c) More agile and digital catering solutions

With the arrival of generations Y and Z, the catering industry has been shaken up by new behavior patterns and new challenges. These consumers have different eating habits and requirements than their parents' generations and expect to be able to eat when they want, where they want, and how they want. To meet these new needs and hold on to its leading position, the Group needs to constantly adapt and innovate.

The changes are particularly noticeable in corporate catering. With the massive arrival of generation Y in the workplace, combined with the explosion of digital technology and new collaborative working methods, the ways companies are run and their working patterns are evolving. People's attitudes to food are also changing, and eating fresh, healthy and high-quality produce in attractive and relaxing spaces has now become essential. Elior is adapting to these changes by offering new concepts.

Despite its young age, generation Z is similarly making its mark and paving the way for new consumption patterns. So Elior has rolled out numerous initiatives to meet that generation's needs. In France, Elior has launched the Weekly Daily offering - an alternative to traditional self- service catering for high school pupils and students. Aimed at young guests in a post Covid-19 context, this new customizable and responsible offering seeks to provide a state-of-the-art digital catering experience, developed especially to meet new consumer trends among young people. Guests select their menu from a wide variety of recipes that can be ordered on the dedicated app and either eaten on site or taken away.

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The Covid-19 pandemic has heightened demand for more flexible, grab & go and digital catering solutions. In all of our host countries, we are fast-tracking our digital transformation process to cater for corporate guests' new eating patterns and give them the foodservice offerings they want. We have developed customized offerings that are compatible with Covid-19 health and safety guidelines to prevent dining areas from becoming too busy while also meeting guests' requirements. The current situation has strengthened our belief that, even more than before, we have to think of new ways of encouraging guests to come or come back to our restaurants, and design new offerings to respond to their new consumption patterns. Guests no longer just come to us automatically; we now have to go and find them, wherever they are. The apps we have developed make our guests' lives easier and make the dining experience relaxed and enjoyable.

In the United Kingdom, Elior UK has deployed an app powered by Dynamify to reinvent its corporate catering operations. Dynamify is a meal pre-order platform that offers a range of services that are proving very popular with corporate guests. Thanks to this simple, intuitive app

  • which consumers can download and configure in less than a minute - social distancing rules can be respected as queues are virtual and payments can be made through the app. The pre-ordering and pre-payment system means that corporate restaurants can give timeslots for contactless collection of orders, therefore limiting the number of guests in the same place at the same time. This also generates significant productivity gains, as staff can process orders more quickly. On average, pre-ordering saves a guest three minutes and catering staff one minute per order.

In France, as soon as the first lockdown restrictions were lifted in May 2020, Elior helped its clients adapt to the strict new health requirements through new, more flexible catering solutions. For example, the Chefs and Go offering allows guests to order fast food in two different ways: click and collect, and click and serve (i.e. delivery within their office building). A total of 120 exclusive recipes have been designed by our chefs for this offering (salads, bowls of food, reheatable dishes etc.). Another concept offered in France is Le self qui s'emporte, which offers a selection of starters, mains and desserts to take away, and is available in self-service restaurants with a dedicated check-out.

Elior Italy likewise drew on new technologies when its corporate restaurants re-openedpost-lockdown. For example, guests can use the JoyFood app - which was developed specially for corporate restaurants - to reserve meals to take away. Payment can also be made through the app, avoiding the use of cash and reducing wait times at the check-out. At the same time, JoyFood makes it easier to manage footfall by providing real-time information

about the number of people in the restaurant and allowing guests to book timeslots. Elior Italy has had another digital offering in place for several years now, specifically designed for small companies - Food360, a self-service system that uses smart fridges. Guests in these companies can now also use the JoyFood app to order and pay for their food and collect it in their own time.

In India, Elior India has rolled out the El Chef app. Thanks to this pioneering innovation in the Business & Industry market in India, guests can compile their favorite menus, view updates and their order history, discover the dishes of the week and plan their meals according to their own specific needs. El Chef will also help our Indian subsidiary to get to know its customers better and therefore to offer them an even better service.

d) Educating tastes

As the pleasure of appreciating food develops from a very early age, the Group is committed to stimulating children's tastes. Our approach to catering for children involves introducing them to new types of foods, proposing varied meals made from high-quality ingredients and serving our food in friendly, modern surroundings.

Our fun approach to nutrition in primary schools was rewarded in the United Kingdom in 2019-2020 when Elior UK's education subsidiary - Taylor Shaw - won the Education Honour at the 2020 Health & Vitality Honours for its Team FAB4 program, which encourages children to adopt good eating habits. Primary school is the perfect time to get children used to eating healthily, which not only boosts well-being but is also better for the environment. Based around four colorful and educational characters, all with their own superpowers, interests and expertise, Taylor Shaw's Team FAB4 program makes learning about nutrition fun for children. They can identify with the four characters, which helps get across the program's key messages, including the benefits of eating more fruit and vegetables, having a balanced diet, trying new food and drinking plenty of water.

Elior UK also took part in the Eat Them to Defeat Them school catering challenge in 2019-2020, which is aimed at inspiring children to eat more vegetables. Focusing on a different vegetable each week, over a period of two months Elior's teams worked with children to sculpt, decorate and disguise all sorts of vegetables to transform them into funny characters, with food counters sometimes looking like scenes from a cartoon. The overall objective of the campaign was to use humor to get kids to love their veg.

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People continue to taste new flavors and try different types of food throughout their lives, and Elior wants to play a role in this ongoing voyage of discovery. So, with a view to surprising and satisfying our guests, we constantly develop new recipes and propose new ways of preparing and cooking ingredients. In the Health & Welfare market in France, Elior organized its eleventh Tout Chocolat baking competition in 2019-2020. Each year, teams made up of Elior chefs and disability care home residents and their care workers compete against each other in a friendly challenge. The idea is for the amateur bakers to create an original recipe, working with professional chefs, and the teams are scored on the originality and taste of their final piece.

We work hard to incorporate a wide range of dietary options into our offerings and we give our guests the opportunity to try out vegetarian, dairy-free or gluten-free dishes. For example, one out of six of the Group's recipes is vegetarian.

e) Delicious food for all locations

Bringing enjoyment to people's lives also means being there for them on cultural outings and at important events.

In 2019-2020, Singularis Catering - the Group's subsidiary that specializes in premium catering for prestigious sites in Spain - won a contract to provide all of the catering services for visitors at the famous MNAC, the national museum of Catalan visual art. For a period of three years, Singularis will be responsible for managing the museum's bar, café and gastronomic restaurant. This new contract was awarded thanks to Singularis's expertise and excellent reputation with many other high-profile clients, and because of its commitment to environmental protection.

Also during the year, Elior UK launched Foodsmiths - its new brand specialized in providing food and hospitality services to visitors and guests at celebrated venues and special occasions. The idea behind creating a brand bringing together all of Elior UK's services for owners and operators of stadiums (e.g. Murrayfield in Edinburgh, the Rangers FC Ibrox Stadium in Glasgow and the Emirates Durham International Cricket Ground), attractions, venues and events (e.g. the Royal Institution in London, the National Museum Cardiff, St Albans Cathedral and Aberdeen Art Gallery) is to accelerate Elior's expansion and build its reputation in this very demanding market. The services Foodsmiths proposes in the cafés, bars and restaurants at these sites and the major events held there are based on the three principles of provenance, craft and quality. The food is cooked freshly on site to create a handcrafted, delicious experience.

In the United States, Elior North America's subsidiary, Constellation Culinary, won the catering contract for the California Academy of Sciences, which is one of the ten largest natural history museums in the world. Already present in many museums and prestigious sites on the East Coast of the USA (from New England to Florida), Constellation Culinary was awarded this new contract thanks to the premium, sustainable and regional offering it designed for the museum, and it will now be able to develop its reputation in California.

In Italy, Elior Italia continued to innovate by proposing vacuum-packed dishes to managers of beach huts and cafés that welcomed back holidaymakers after the country's lockdown was lifted. With over 400 recipes available in modified atmosphere packaging to keep the food fresh, this offering helps the managers of seaside resort facilities to cater for holidaymakers in total Covid- 19 safety with reduced staff numbers. This allowed the managers of the many beach huts and cafés that line the Italian beaches in the summer season to propose high- quality food while respecting social distancing rules, both in terms of staff numbers in the kitchen and contact with guests.

Elior also manages catering services for train passengers and at airport lounges. Serunion runs the VIP lounges at Spanish airports, Elior UK provides on-board catering for three lines of South Western Railway, and Elior Italia provides on-board catering for Trenitalia trains.

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1.7.2 THE GROUP'S STRATEGY

New Elior ambitions

Following the sale of Areas in 2019, the Elior group refocused on its core business of contract catering in six countries, plus services in France. Consequently, we redefined our corporate mission, ambitions and priorities for each of our markets and drew up a strategic plan called New Elior. This plan - which was the outcome of work carried out jointly by the Group's Executive Committee and operations teams - is based on five value- creation drivers:

  • Shifting our business mix towards the most attractive segments, in which we can create value for our clients through innovative offerings, and entering new markets, such as on-board catering for trains and meal deliveries to Small and Mid-size Enterprises (SMEs).
  • Giving our client-facing teams the resources they need to always adapt our offerings to guests' expectations, by proposing healthy and environmentally-friendly dining options, with concepts heavily inspired by commercial catering and drawing on online digital experience with Food Tech standards.
  • Being constantly customer-centric thanks to our high-quality offerings and by systematically applying customer loyalty best practices.
  • Optimizing and continuously adapting our cost structure to operational requirements, including procurement, payroll and overhead costs.
  • Managing cash in a disciplined way and allocating investments to opportunities that guarantee the best returns.

With its New Elior plan, the Group had already begun its transformation process before the outbreak of Covid-19. The health crisis has accelerated the implementation of the plan but has not affected any of its fundamental principles. Some of the initial assumptions used in the plan have been revisited, however, in view of the current context, particularly the target market segments on which the Group intends to focus its expansion, due to opportunities that have emerged. For instance, outsourcing levels are expected to increase in some Education and Health & Welfare market segments where the in-house management model still dominates in several countries.

It is the Business & Industry market that will experience the most significant and lasting impacts of the crisis, and the Group has therefore accelerated its work on reinventing its offerings in this market in response to new working organizations, drawing on digital assets to achieve best market practices.

Going forward, Elior expects to see a gradual recovery in the economy in the mid-term, with a rebound once the crisis is over and additional revenue generated by its new offerings, which will enable the Group to return to a solid level of growth and improve its pre-Covid margins.

1.7.2.1 Key features of the contract catering market

In the countries and sectors where the Group is present, the contract catering market (also referred to as outsourced catering) represents a potential of €130 billion. As the outsourcing rate is 42% this implies that the market currently represents €55 billion.

The key features of the worldwide contract catering market are as follows:

  • It is a market that is expected to continue to grow globally, with different growth rates for the various market segments as some segments will be more affected than others by the Covid-19 crisis. In general, the growth of a given segment depends on:
    1. Changes in the number of meals served.
    2. Inflation and changes in per-meal prices.
    3. Changes in outsourcing rates, i.e. the proportion of clients who outsource their catering services rather than managing them in-house.
  • It is a local market with a fairly limited number of multi-country invitations to tender as these do not generate operational synergies.
  • It is a specific market, with invitations to tender for catering services rarely combined with other types of services, particularly in Continental Europe, the main exception being in the health & welfare sector.
  • Before the Covid-19 crisis it was a market that had low barriers to entry, apart from in the state education sector, where operators in most countries need to invest in central kitchens. The impact of the crisis on the Business & Industry segment has led the Group to speed up its transformation process and the diversification of its offerings. In addition, stricter health and safety protocols will favor large players.

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  • It is a market with increasingly diverse and mobile service models (click and collect, etc.), driven by the faster penetration of digital technology.
  • In most countries the market is structured around four main corporate profiles: international groups, like Elior; large companies with national coverage; regional local players; and players specialized in a particular segment.
  • Lastly, it is a market in which guests' expectations change in line with trends in society. The current health crisis has accelerated this underlying movement, with consumers paying increasing attention to sustainability (local sourcing, the fight against food waste, the role of caterers in the community, etc.), nutritional balance and transparency. To meet these expectations, the supply chain and digital technology are indispensable factors, particularly for millennials, who are expected to represent 50% of the new hires taken on by the Group's major corporate clients in 2020.

1.7.2.2 Key features of the services

market

Services correspond to the Elior group's second-largest business. Elior Services is a major player in cleaning, healthcare hospitality and facility management (reception, mail and concierge services, etc.) in France.

The outsourced cleaning and related services market in France represents an estimated €30 billion (2017 data), with an outsourcing rate of around 45%.

The key features of this market are as follows:

  • Low barriers to entry and low capex requirements.
  • High fragmentation: companies generating over €100 million in revenue have a market share of approximately 35%, and 90% of companies in the market had less than 10 employees in 2014 (data source: Xerfi).
  • Steady annual growth of around 2% to 3%.
  • Very high weighting of payroll costs within the overall cost structure, and therefore sensitivity to changes in tax and social security laws and regulations.

1.7.3 THE GROUP'S COMPETITIVE STRENGTHS

As a leading player in contract catering and services, the Group believes that it has major competitive strengths, which have been reinforced by certain effects of the Covid- 19 crisis, particularly in relation to smaller-sized players.

1.7.3.1 An operating presence in growing markets with attractive fundamentals

1.7.3.1.1 Solid competitive positions in Europe, complemented by an operating presence in the buoyant US market

In the six main countries where the Group operates, contract catering is characterized by a highly competitive environment, with a large number of small and mid-size regional or specialized operators competing with a few national or international players. In the Group's markets, critical mass is an essential competitive factor, as it creates the ability to offer prices that match market expectations. At the same time, large players such as Elior are better equipped to compete for major contracts.

Thanks to its assets and financial solidity, the Group believes that it can consolidate its positions in a context where smaller-sized players are less attractive, are struggling financially, and have limited investment

capacity to transform and adapt to the post-Covid-19 environment.

Lastly, the higher number of stricter health and safety standards resulting from the crisis requires resources and expertise that larger groups tend to have.

a) In Europe

The addressable contract catering market in the European countries where the Group operates is estimated to represent almost €43 billion, of which only around €21 billion is currently outsourced. In all of the countries and sectors in which the Group operates in Europe, it has been able to reach critical mass and position itself among the main market participants. The Group's leading positions and its emergence as a local or national champion in almost all of its business sectors and host countries in Europe have been made possible due to a decentralized organizational structure that encourages a local entrepreneurial culture while drawing on the support functions provided by the Group (procurement, finance, human resources, communications, innovation, digital and IT). The organizational and operational model for support functions is aimed at aligning best practices in order to deploy them Group-wide and accelerate the

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implementation of the New Elior plan in response to the current unprecedented health crisis.

Based on revenue for fiscal 2019-2020, the Group estimates that:

  • In France it is the leader in contract catering and the leader in cleaning services for the healthcare sector.
  • In Spain it is the leader in contract catering.
  • In Italy it is the leader in contract catering.
  • In the United Kingdom it is the fourth-largest contract caterer.

b)In the United States

The Group has a solid presence in the United States, where it first entered the contract catering market in 2013 via its acquisition of TrustHouse Services (since renamed Elior North America). The US market represents a major growth driver for the Group, thanks to the solid positions it enjoys in the most attractive market segments of the contract catering industry. The Group has consolidated its position as the market's fifth-leading operator, notably as a result of the acquisitions it has carried out over the past three years.

1.7.3.1.2 Market dynamics still promising over the long term for contract catering and services

The Group is present in markets and sectors that tend to have high growth potential. In Europe, it estimates that the addressable contract catering market in which it operates is worth approximately €21 billion. In the United States, the addressable contract catering market in the sectors in which the Group operates is estimated at $92 billion, of which only $36 billion is currently outsourced (corresponding to an outsourcing rate of just 40%). The Education market (particularly in the United Kingdom) and the Health & Welfare market (in the United Kingdom, Spain and Italy) also represent strong growth potential, with outsourcing rates still below 50%. Due to the Covid- 19 crisis, the Group expects to see an increase in outsourcing, which it believes will drive growth in the coming years.

In order to create growth drivers, the Group analyzes the trends in each of the contract catering and services markets in which it operates, some of which have accelerated due to the current health crisis. For example, the Group believes that:

  • The reorganization of work spaces and ways of working will have a lasting impact on consumption patterns in the Business & Industry market. In the private sector, again in the Business & Industry market, high-street brand and grab and go concepts, which were already popular before the crisis has been a faster pace of development of new services based on digital technology (click & collect and take-away solutions, etc.), enabling catering services to cover wider areas and broader timeslots. The Group intends to make up for its reduced business volumes by increasing the capture rate at its sites and building up these new services.
  • In the Education market, the move towards outsourcing will gain speed, in particular for secondary schools and universities, which still have relatively low outsourcing rates, especially in Italy, France and the United Kingdom.
  • The Health & Welfare market will continue to grow, notably in France and the United States, due to general population aging, the market's still relatively low outsourcing rates, and the further development of value-addedsub-segments, such as home meal deliveries, hospital after-care services, and new services related to an expected trend towards higher- end offerings in elder care facilities.
  • The Services business will continue to grow, driven by the combined effect of (i) an increase in outsourcing, as clients seek ways to reduce costs, (ii) constraints related to an ever-stricter and more complex regulatory framework in this sector, and (iii) more stringent health and safety measures.

1.7.3.2 Carefully chosen strategic fit between contract catering and services

1.7.3.2.1 Two businesses with

complementary features

The Group's two businesses have different financial models which require different types of management. The New Elior plan was structured using the same framework but independently for each business.

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Commercial synergies

Commercial synergies between the contract catering and services businesses in France are generally limited and highly targeted. They mainly concern the health sector, in which joint service offerings can help meet the challenges arising from changes in the ways that hospital care is dispensed, particularly for short stays (e.g., delivered meals which are then served to patients in their rooms).

Sometimes, especially for key accounts, comprehensive catering and hospitality service offerings can help the Group stand out from its competitors, as was the case for the Airbus University in Toulouse.

Operational synergies and shared resources

Operational synergies between the two businesses mainly concern maintenance operations for some technical equipment in kitchens, which can be carried out by Elior Services on an outsourcing basis.

Certain support functions (mainly IT and procurement) are shared between the two businesses.

Financial models

There are also differences in the two businesses' financial models. For instance, the weighting of purchases of equipment and consumables within the cost structure of the services business is much lower than for contract catering. However, they both have low capital intensity (especially services) and low working capital requirement, and therefore a high cash generation profile.

Image and reputation

Lastly, the Group's Elior and Elior Services brand names are growing more powerful in its business sectors and markets, which means that it can capitalize on the reputation for quality and excellence it has built up in certain operations over many years. The strong resilience shown by the Group's services businesses during the health crisis enabled it to maintain high business volumes in the Health & Welfare market.

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1.7.3.2.2 Growth opportunities across all of the Group's operations, fueled by higher production capacity and stronger innovation capabilities

In 2019, the New Elior strategic plan allowed the Group to define three growth priorities.

The first of these priorities concerns the most attractive market segments to which Elior had already shifted its focus. As the lasting effects of the Covid-19 crisis will vary from one sector to another, in 2020-2021 the Group will readjust its target growth segments.

The second growth priority entails market segments that are related to the Group's core business. Some of the related segments originally selected in the New Elior plan

  • such as airline companies, leisure venues and cultural venues - remain heavily impacted by the crisis. The Group is therefore seeking out other related services to act as mid-term growth drivers until business returns to "normal".

The third priority is to develop business with clients who have so far opted for in-house management of their catering and/or cleaning (in France). Due to the Covid-19 crisis, the Group expects to see an increase in demand for outsourced services from these clients, mainly in the Health & Welfare market and some segments of the Education market.

Lastly, as mentioned above, the current health situation and the economic impacts of the crisis will strengthen the competitive positions of large groups like Elior.

On-board train catering (a market worth around €500 million in Europe) is another related service the Group has decided to leverage as part of its business development drive. Having provided the Itinere on-board train catering offering for Trenitalia in Italy since 2013, Elior managed to transpose its know-how in this area to the United Kingdom, winning its first multi-year contract in the country, for trains on the East Midlands line operated by its partner, Trenitalia.

The Group's objectives for the related services it has already targeted and that it may target in the future due to the Covid-19 crisis have been set on a local basis for each of its host countries. Their development in terms of their sales pipeline and their weighting in the various subsidiaries' business mixes is being tracked via the Group's CRM systems.

In order to drive profitable growth in these segments the Group has placed innovation at the heart of its operational strategy. Our approach is aimed at mobilizing, training

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and equipping our managers so as to accelerate our innovation capacity and maximize value creation. It is based on three pillars which will continue to apply in fiscal

2020-2021:

  • "Think": staying up to date with the latest innovations thanks to trend intelligence and a digital platform grouping all players and innovative projects in the foodtech services ecosystem; mobilizing leaders and operations managers to devise the offerings and services of tomorrow through working groups using Design Thinking processes and methods; and encouraging information sharing and feedback via events or digital tools in order to capitalize on best practices and accelerate the Group's innovation capacity.
  • "Test": continuing to transform our restaurants and client sites into veritable incubators with a view to testing and jointly creating innovations with our clients; and pursuing our intrapreneurship strategy, which values and rewards the creative potential of our teams and gives our people the innovation momentum required for our value creation drivers. A prime example is the project that won the 2019 Innovation Awards: called Cheatah and launched by Elior UK, this solution clearly fits with the Group's strategy of diversify catering methods as it offers an online, on-site delivery service at university campuses of pizzas freshly prepared by Elior's chefs.

At the same time, the Group is continuing to deploy its Open-Transformation strategy, drawing on strategic partnerships to help reinvent itself. For example, Arpège - the Group's premium brand in the French Business & Industry market - has entered into a partnership with the culinary incubator United Kitchens, aimed at developing innovative, responsible and original food. Together, Arpège and United Kitchens are creating virtuous concepts for the future in areas such as working with unprocessed and seasonal produce, fighting food waste and contributing to social inclusion.

  • "Do": supporting the deployment of mature projects and cutting-edge concepts; and providing training in the Group's innovation methods and tools and in the practices of commercial catering. In line with this, Elior UK has rolled out a training program at over 400 sites called "Right track", aimed at giving site managers the keys to energize sales and stay up to date with the latest trends.

1.7.3.3 A resilient business model thanks to a loyal client base and long-term contracts

Complementary geographies and markets

The resilience of the Group's business model is mainly due to the wide diversity of its operations in terms of markets and geographies. For example, in contract catering, the Health & Welfare and Education markets are less exposed to economic cycles or the lasting impacts of the Covid-19 crisis than the Business & Industry market. The Group expects that for Business & Industry clients - which mostly manage their catering services in-house - the current health crisis will lead them to accelerate the outsourcing of those services, which would represent a growth driver for Elior.

Seasonal reductions in guest numbers in certain markets (notably Education and Business & Industry) can be partly offset by increases in other sectors for which holiday periods are the high season, such as daycare facilities during school vacations.

Business volumes for Elior Services, on the other hand, are more stable throughout the year as its client contracts are mainly entered into on a flat-fee basis and around half of its revenue is generated in the Health & Welfare segment.

Long-term contractual relations with clients

The Group's business model is also strengthened by the fact that it has a wide and diverse client portfolio. In 2019- 2020, its five largest contract catering clients accounted for less than 7% of total consolidated revenue.

Other factors that contribute to the strength and stability of the Group's business model include the structure of the contracts underlying its contract catering operations, as well as the existence of stable and long-lasting relations with a large number of its major clients. The fast response of the Group's teams to the Covid-19 crisis and their hard work to ensure continued service quality and implementation of the requisite health and safety measures were recognized and highly appreciated by clients, which has further strengthened client relationships. Many of the Group's contract catering contracts include automatic renewal clauses and indexation clauses based on the prices of certain raw materials and labor costs. The Group also has very longstanding relations with a number of large international corporations, such as Airbus, Trenitalia, Seat and Ramsay Santé and major public-sector agencies, such as the Hauts- de-Seine municipal authorities in France. Our teams are building even closer relations with each of their clients in order to understand their challenges, constraints and needs in the current situation and provide bespoke solutions that provide the best possible support with

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helping to transform their business organizations. For the year ended September 30, 2020, the Group's client retention rate for contract catering operations was 91.8%, or 92.6% excluding voluntary contract exits, mainly in Italy and the reduction in the scope of the Tesco contracts in the United Kingdom.

The Covid-19 crisis has been a period in which the Group has been able to further tighten both the quality and stability of its client relations, by offering them solutions and services tailored to their specific needs during these unprecedented times. These include providing alternatives to on-site production, introducing digital order and payment systems and creating Covid-safe dining spaces.

From the very outset of the crisis, the Group began renegotiating all of its contracts in all of its host countries in order to mitigate the effect on profitability of lower business volumes. The renegotiations were particularly focused on clients taking on residual fixed costs during the lockdowns and the periods when lockdown restrictions were gradually lifted.

The Group's mid-term objective is to offer its clients not only its traditional catering services, but also a portfolio of alternative offerings and solutions that fully meet the new needs and expectations that have emerged with the crisis, both in terms of health and safety and working from home.

1.7.3.4 A proven capacity to create value, combining organic and acquisition-led growth and a recognized ability to effectively integrate acquired companies

The Group has a strong track record in terms of acquisitions, and since early 2016 the new businesses it has acquired have added some €900 million to annual consolidated revenue.

The success of these acquisitions is due to the profiles of the target companies and their strategic fit with the Group's existing operations. This is illustrated by the latest business combinations carried out both in the United States (which have extended the Group's geographic coverage in that country and strengthened its positions in specific market segments) and in the United Kingdom (resulting in greater coverage of the Health & Welfare and Education markets). The integration process for newly-acquired companies includes plans for leveraging synergies, which are assessed upstream of the transaction and encompass areas such as costs (procurement, IT, support functions, etc.), business development (integrating acquired brands into the Group's portfolio, analyzing client portfolios, capital

expenditure projects, etc.), human resources, and management. In most cases the Group keeps the existing management teams in place, in order to ensure continuity and encourage an entrepreneurial culture.

The Group's acquisitions have enabled it to create national champions in each of its main host countries. One illustration of the effectiveness of this strategy is the ramp-up of its contract catering operations in North America. Having first entered the market in 2013 through the acquisition of THS, the Group was the fifth-largest contract caterer in North America at September 30, 2019.

1.7.3.5 Operating excellence resulting from a tightly-controlled supply chain and cost base

The Group's cost base mainly comprises purchases of food products and raw materials, personnel costs and overheads. Faced with reduced footfall in the Business & Industry market due to the impact of new working organizations, and in view of the fact that clients will be seeking cost savings, the Group is working on proposing solutions to agilely manage fluctuations in volumes while maintaining its profitability despite lower business levels.

A tightly-controlled supply chain

Because of the large economies of scale resulting from its size and geographic reach, the Group is able to obtain highly favorable purchasing conditions and significant rebates, therefore increasing its cost efficiency compared with other market players. In addition, it has stable and long-lasting business relations with the majority of its local and global suppliers of foodstuffs, other raw materials and logistics services.

The Group strictly monitors the quality of its supplies, notably by performing quality audits when selecting new suppliers and periodic audits on existing suppliers, and by carrying out regular controls on the raw materials and products that it purchases.

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Constant cost control

Cost control and continuously improving on-site operating efficiency are priorities for the Group and key measures of its successful management. As well as implementing upstream procurement policies, the Group has put in place processes to optimize the use of purchased foodstuffs on site in order to minimize waste.

In addition, as personnel costs represent the largest proportion of its cost base, the Group closely monitors movements in its overall payroll in order to ensure it keeps up its cost efficiency during local market cycles. During the Covid-19 crisis, the Group worked on making its wage costs more flexible with the aim of improving its agility post-crisis so that it can respond to volatility in demand, which is expected to be ongoing, especially in the Business & Industry market.

1.7.3.6 Experienced management teams with an entrepreneurial mindset and in- depth knowledge of their markets

The Group's highly decentralized organizational structure means that its managers have a resolutely entrepreneurial mindset. They share the Group's financial objectives and take part in certain strategic initiatives but they remain autonomous from an operational and commercial point of view, which gives the Group a dynamic and agile profile. The New Elior plan - which is structured around five value creation drivers that apply Group-wide, with specific objectives for each country - is a clear illustration of this approach.

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1.7.4 THE GROUP'S MAIN OPERATING MARKETS

1.7.4.1 The Business & Industry market

Contribution of the Business & Industry market to the Group's 2019-2020 consolidated revenue

41%

59%

Business & Industry

Other

Key Figures

  • No. of sites: 3,635

No. of restaurants and points of sale: 5,633

  • No. of guests per day: 1.1 million
  • Elior's position in the Business & Industry market in its operating countries (contract catering)
    France: no. 1, Italy: no. 1, UK: no. 4,
    Spain: no. 2, USA: no. 5
  • Client base:

Trenitalia, Enel, Hera, Poste Roma, World Food Programme, Seat, La Poste, Amadeus Sophia, Airbus, Renault, California Academy of Sciences, The Carnegie Hall Corporation, Wimbledon Football Club, New York Botanical Garden, Linklaters, BAE Systems, Apollo Global Management, Phoenix Zoo, Sanofi, Bank of England, Scottish Rugby Union Limited, Futbol Club Barcelona, Ashok Leyland, PayPal, etc.

Elior proposes catering services and cleaning services (in France) to businesses in all types of sectors, ranging from manufacturing to financial services, and of all sizes, from SMEs to international corporations, adapting its offerings to their varied and specific needs. The Business & Industry market comprises several segments, which have different levels of exposure to economic cycles and the lasting impacts of the Covid-19 crisis.

Offerings adapted to all business segments

We are keenly aware that the needs and expectations of our clients and guests differ depending on their profiles, for example whether they operate in the manufacturing or services sector. We are agilely adapting our production and service models to accompany the changes in work organization methods that were already happening pre- Covid and are accelerating as a result of the crisis. In addition, as a benchmark player in industrial ultra- cleaning, Elior Services provides cleaning and hygiene services for production areas and highly specific environments such as white rooms.

Specific offerings for government agencies

We also provide services that are tailored to the specific needs of different types of government agencies (e.g. 7/7 and night services), including ministries and regional authorities, as well as military bases and correction facilities.

Eating well, even on the move

We have built up real expertise in on-board rail catering - starting out in Italy and then in Spain and the United Kingdom - with original offerings made from fresh and seasonal produce. Passengers can sit down to eat or can grab & go, or book a meal online for direct delivery to their seat. An even broader range of services is now available on night trains, including packed meal boxes and bed- making.

Sport and leisure

We offer both sit-down dining and snack options to enjoy at venues such as stadiums (Murrayfield, etc.), zoos, museums and prestigious cultural sites (the Vatican, for example).

Source: Elior Group

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1.7.4.2 The Education market

Contribution of the Education market to the Group's 2019-2020 consolidated revenue

29%

71%

Education

Other

Key Figures

  • No. of sites: 6,499
  • No. of restaurants and points of sale: 14,122
  • No. of guests per day: 2.1 million
  • Elior's position in the Education market in its operating countries (contract catering)
    France: no. 1, Italy: no. 3, UK: no. 4,
    Spain: no. 1, USA: no. 5
  • Client base:

Comune di Pisa, Comune di Genova, Ville d'Issy-les- Moulineaux, Collège Stanislas, Ville de Lyon, London Business School (LBS), University of Roehampton, Conseil départemental des Hauts-de-Seine, Lycée français de Madrid, L'Oréal Madrid, RTVE, Télécom PariTech, Les Petits Chaperons Rouges, Savannah State University, Madison County Schools, Akron Public Schools, etc.

Source: Elior Group

The Education market comprises three main segments (pre-school; elementary, middle and high schools; and higher education) and our clients in this market include both state-run and private establishments.

The central kitchens network - a powerful asset

The Group's historic clients in the Education market are local authorities, which for a long time have outsourced their catering to organizations that can guarantee a high level of food safety and constant production volumes, with the necessary logistics capabilities. With 121 central kitchens in France, Spain and Italy, we have the largest central kitchen infrastructure in Europe, with regional coverage that enables us to combine high productivity with a local presence. These kitchens prepare and deliver several hundred thousand high-quality meals a day. We have recently created a new generation of central kitchens

  • Les Pépinières du Goût - which focus on training and sustainability and are underpinned by three key commitments: taste, service quality and respect for the environment.

Catering solutions for every age

Thanks to the expertise we have honed over the years, we offer innovative catering solutions tailored to the specific needs of each age group, from pre-school right through to university. We offer comprehensive catering solutions to help children make good food choices by themselves. And we are committed to providing transparent information about allergens (e.g. the Lunchhound solution in the UK) as well as the origin of the food we serve and its nutritional values (as illustrated by the rollout of the Nutri-Score system in France for example).

Giving children a taste for healthy eating

The ingredients we use are selected by dieticians who ensure that our menus are balanced and varied. In order to help us propose innovative and diverse menus, in France, 10 new recipes are tested every month by a panel of 50 children. We also organize nutritional campaigns and anti-food-waste events to get the healthy and responsible eating message across to children, such as "Let's have breakfast together", which helps children understand how important it is to eat breakfast, and "Vegetable day". During the year we also developed and launched a flexible home meal pack program offering breakfast and lunch for two, three or five days depending on the home-learning schedules of the schools concerned.

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1.7.4.3 The Health & Welfare market

Contribution of the Health & Welfare market to the Group's 2019-2020 consolidated revenue

30%

70%

Health & Welfare

Other

Key Figures

  • No. of sites: 2,371

No. of restaurants and points of sale: 2,972

  • Number of guests per day: 0.6 million
  • Elior's position in the Health & Welfare market in its operating countries (contract catering)
    France: no. 2, Italy: no. 1, UK: no. 4,
    Spain: no. 1, USA: no. 5
  • Client base:

Hôpital Foch, Ramsay Santé, Cancer Campus Gustave Roussy, Ospedale Luigi Sacco, Barts Health NHS Trust, CHU de Toulouse, Allegheny Valley Hospital, Louisiana Department of Health, Association Entraide Universitaire, Hospital Universitario de Burgos, etc.

Source: Elior Group

The Elior Group 1

The Group's Businesses and Strategies

The Health & Welfare market covers the following main segments: health (public hospitals and groups of private clinics), seniors, residential homes and day-care centers for disabled and/or dependent people, and non-profit organizations that provide community meal services.

Taking care of dependency

Some elderly care home residents and people with disabilities are dependent, which means they have difficulties with basic actions, such as eating or drinking. To help make their everyday lives easier, we have designed specific solutions both for their meals (such as texture- modified foods) and their other needs (Elior Services' hospitality solutions).

Eating well to get better

A healthy, balanced diet is often the first step to getting better. At Elior, we design concepts tailored to each type of patient and resident depending on their specific needs (e.g. for the elderly and people with disabilities) or on their pathology (cancer, Alzheimer's, etc.). We also address the public health problem of malnutrition by creating concepts such as Énergie Saveurs in France, which offers specially enriched food, and Elior Italia's NutriAge concept. NutriAge - which includes an initial nutritional diagnosis, personalized menus and long-term monitoring

  • has established Elior Italia as a veritable partner for care homes for the elderly and their residents in the fight against malnutrition and weight loss.

Championing autonomy and social inclusion

We partner our clients in health and welfare establishments in designing innovative solutions that help their residents and patients either retain or regain their independence. We also distribute meals for charitable organizations and centers for vulnerable people. And during the Covid-19 crisis, we reacted quickly to help people in need, notably through our TRIO Community Meals brand in the United States.

Fostering synergies between businesses

Health & Welfare is the market that offers the most opportunities for leveraging synergies between catering and services, such as meals served in rooms. Elior Services' offerings comprise many high added-value services, including specialized cleaning and a wide range of hospitality services (concierge services, pre- and post- hospitalization support, etc.).

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1.7.5 GEOGRAPHIC MARKETS

1.7.5.1 Contract catering in France

With estimated addressable revenue of over €7.2 billion in 2018 (data source: Gira), and based on external data, the Group believes that it is the leader, in front of Sodexo, in the French contract catering market, holding the leading position in Business & Industry and Education, and second position in Health

  • Welfare (based on outsourced sales in 2018). The French market is relatively concentrated, with the three largest players accounting for 68% of its overall sales in 2018. The Group's main competitors in the French contract catering market are large multinationals, such as Sodexo and Compass, but it also faces competition from smaller national caterers such as Api Restauration, Dupont and RestAlliance.

The outsourcing rate in France corresponds to approximately 37% of the overall in-house and contract catering market, which the Group estimates was worth approximately €19 billion in 2018, up almost 2% year on year. The French market has experienced sustained growth of 2% a year since 2015.

1.7.5.2 Services in France

France is the Group's principal geographic market for its Services business. The Group estimates that the French cleaning services market generated over €25 billion in

revenue in 2017, around €12 billion of which derived from the outsourced segment of the market, representing an outsourcing rate of approximately 48%. It also estimates that sales generated by the outsourced cleaning services market in France are still growing at an annual rate of between 2% and 3%.

On the basis of research carried out by external agencies at the Group's request, the Group considers that specialized cleaning services represented 40% of the overall revenue generated by the cleaning services market in France in 2016, versus 60% for standard and office cleaning services (data source: Le Monde de la Propreté).

The Group believes that the French cleaning services market is highly fragmented, with around 45,000 companies referenced (data source: Le Monde de la Propreté). Players generating less than €100 million in revenue together account for almost 65% of the market's total revenue.

The Group's Services business faces competition from large, multinational providers such as Sodexo and ISS, as well as from smaller, regionally-based service providers.

Key Figures

Market positions

Elior Services key figures

No. 1

No. 1

2,301

20,354

in contract catering

in cleaning services for

sites

employees

the healthcare sector

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1.7.5.3 International contract catering

In the six main countries where the Group operates (France, Italy, Spain, the United Kingdom, the United States and India), contract catering is characterized by a highly competitive environment, with a large number of small and mid-size regional or specialized operators competing with a few national and international players. In the Group's markets, critical mass is an essential competitive factor, as it creates the ability to offer prices that match market expectations. At the same time, large players such as Elior are better equipped to compete for major contracts.

Key Figures

5

countries

(excluding France)

Market positions

No. 1

No. 3

No. 4

No. 5

in Spain and Italy

in Europe and India

in the United Kingdom

in the United States

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1.7.6 LAWS AND REGULATIONS APPLICABLE TO THE GROUP

The Group is subject to various laws and regulations issued by local, national and other government entities in each of the countries in which it operates, as well as at European Union level (the "EU"). Its contract catering business is particularly subject to laws and regulations regarding hygiene, food safety and food labeling.

Additionally, the Group is subject to labor and employment laws and regulations across all of its operations and host countries.

In 2020, new laws and regulations were introduced in the countries where the Group operates as part of the fight to contain the spread of Covid-19. For example, in Italy a temporary governmental decree was published which almost totally prohibited the movement of people throughout the country. A raft of rules and guidelines have also been issued concerning social distancing, wearing face masks and limiting the number of people in the workplace.

In response to the crisis, the Group introduced new health and safety protocols in all of its host countries to ensure a safe environment for its clients and employees. In the United Kingdom, the Group's Covid-19 safety measures were officially approved by the Cheshire East Primary Authority, and in Italy, Elior developed its Covid-19 safety plan in collaboration with the University of Milan. In France, a Covid-19 prevention guide was drawn up in association with Dr. François Henri Bolnot and its content was approved by the Group's occupational physician.

The quality of Elior Services' processes have been certified by MASE and the Group's procedures in Spain by AENOR.

1.7.6.1 Food safety regulations

Food safety is a fundamental aspect of the Group's business as a food services provider. Serving food that is safe and has been prepared and distributed in accordance with the applicable regulations is an underlying prerequisite for clients and is the foundation for the trust they place in the Group. In its contract catering operations, the Group is subject to extensive laws, regulations and other requirements relating to food safety, hygiene and nutrition standards in each of the countries in which it operates, whether at local, national or EU level (for its operations in the European Union).

1.7.6.1.1 Food safety and hygiene

a) European Union

A set of rules known as the "Hygiene Package" has been applicable in the European Union since January 1, 2006. The introduction of this legislation was aimed at creating a single, transparent hygiene policy applicable to all food and all food operators right through the food chain "from farm to fork", together with effective instruments to manage food safety and any future food crises throughout the food chain.

For its catering operations the Group is subject to five of the Hygiene Package's regulations:

Regulation (EC) No. 178/2002 dated January 28, 2002 (also called the "General Food Law") lays down the general principles of food safety and covers foodstuffs intended for human consumption and animal feed. This Regulation also established the European Food Safety Authority (EFSA) and the Rapid Alert System for Food and Feed (RASFF) in the European Union.

The EFSA assesses and communicates on all risks associated with the food chain in order to provide guidance and clarity for the policies and decision making of food safety risk managers. A large part of the EFSA's work entails issuing scientific opinions on matters that affect food safety. The EFSA uses its expertise in playing an advisory role for European legislation on food safety, deciding whether to approve regulated substances such as pesticides and food additives and developing regulatory frameworks and policies in the field of nutrition.

The RASFF is an alert system that warns each EU country's health authorities whenever a risk is identified for a food product.

The General Food Law establishes general principles (e.g. use of risk analyses by the relevant authorities, the precautionary principle, the principle of transparency and the protection of consumers' interests) and sets out specific obligations for professionals, including traceability, recalling any products that may present a public health risk, and informing the relevant inspection authorities.

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In particular, the General Food Law requires food business operators to ensure that businesses under their control satisfy the relevant requirements and to verify that such requirements are met at all stages of production, processing and distribution. It also imposes a mandatory traceability requirement along the entire food chain that applies to all food and all types of operators in the processing, transportation, storage, distribution and retail stages. Each food operator is required to register and retain for a period of five years detailed product information (including the name and address of the producer, the nature of the product and the transaction date) and make such records immediately available to the relevant authorities upon request.

Regulation (EC) No. 852/2004 dated April 29, 2004 on the hygiene of foodstuffs applies to all food businesses (including caterers, primary producers, manufacturers, distributors and retailers).

This Regulation requires, among other things, that food chain players set up procedures based on the principles of Hazard Analysis Critical Control Points (HACCP) which should take account of the seven Codex Alimentarius principles (a program set up jointly by the United Nations Food and Agriculture Organization (FAO) and the World Health Organization). HACCP is a process control system which is used to identify potential food safety hazards and take action to reduce or eliminate the risks related to the various stages of the product manufacturing process, including ensuring the safety of raw materials, validating internal processes, shelf life and end-consumer usage. The Regulation also requires that employees undergo training on food hygiene matters and the application of HACCP principles. In addition, it sets out obligations for meal- delivery firms in terms of declaring and registering food information with the food control authorities and requesting authorizations.

Regulation (EC) No. 853/2004 dated April 29, 2004 includes more stringent requirements for food products of animal origin, such as meat, fish and dairy products, and foods containing such products. European legislation regulates the temperature settings at which these products must be kept as well as the length of time for which they can be displayed.

Regulation (EC) No. 2073/2005 dated November 15, 2005, as amended by regulation (EC) No. 2019/229 dated February 7, 2019, is an implementing regulation covering microbiological criteria for foodstuffs. These criteria are used for assessing the compliance of products when setting the shelf life of products or for health and hygiene controls.

Regulation (EC) No. 2017/2158 dated November 20, 2017, establishing mitigation measures and benchmark levels for the reduction of the presence of acrylamide in food.

b)France

In France, the main food safety regulator is the Agency for Food, the Environment and Occupational Health and Safety (Agence Nationale de Sécurité Sanitaire de l'Alimentation, de l'Environnement et du Travail, or "ANSES"). ANSES is a governmental agency that is overseen by the Ministries of Health, Agriculture, the Environment, Labor and Consumer Protection. It acts as a watchdog and advisory specialist for a wide range of issues related to human and plant health and animal health and welfare, and also carries out research activities in these areas. It applies a holistic approach to health issues by analyzing all of the related risks and benefits. It assesses all of the risks (chemical, biological, physical, etc.) to which an individual may be exposed - voluntarily or involuntarily - at all ages and times of their life, whether at work, when traveling, during leisure time, or through the food they eat.

French food safety regulations incorporate the standards provided for in EU legislation on food safety. They also include the requirements of:

The governmental decree of December 21, 2009 (consolidated version of May 25, 2020) concerning the temperature settings at which animal-derived products must be kept, and specific provisions relating to contract catering establishments (display dishes, the obligation to report to the authorities any suspected cases of food poisoning, procedures for managing unsold food etc.), supplemented by the decree dated October 8, 2013 relating to foodstuffs that are not derived from animal goods.

The governmental decree of February 2, 2015 relating to the definition of the concept of local distribution, implementing Regulation (EC) No. 37/2005 and rescinding the decree dated July 20, 1998 setting the technical and hygiene conditions for food transportation.

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The governmental decree of June 8, 2006 concerning health and hygiene ratings for companies that market products of animal origin and foodstuffs containing animal products, as amended by decree on May 19, 2020.

In addition, Elior France is subject to certain provisions of the French Rural Code (Code rural) dealing with food safety, epidemiology concerns related to products of animal origin, animal feed, and animal health.

Elior France also has to follow the instructions issued by the French Food Safety Agency ("DGAL"), notably:

  • Technical Instruction DGAL/SDSSA 2019--38 dated January 1, 2019, which merges all of the DGAL memoranda relating to the approval procedure provided for in Regulation (EC) No. 853/2004. This instruction particularly specifies the approval procedure to be followed by central kitchens, events caterers and group cooking workshops, as well as the terms and conditions applicable for the Agency's delivery and tracking of health and hygiene certifications.
  • Technical Instruction DGAL/SDSSA/2020 - 289, which specifies the health and hygiene regulations applicable to retail trade and the transportation of animal-origin products and foodstuffs containing animal products. It presents the consequence of synchronous amendments to several ministerial decrees, including those of December 21, 2009 and April 12, 2017 defining the foodstuffs that cannot be included in donations to charitable organizations. It also merges and updates information previously included in several separate technical instructions in order to take into account recent regulatory and infra-regulatory developments.
  • Technical Instruction DGAL/SDSSA/2019-861, which provides a general description of the resources available to food industry players for determining, validating and verifying the microbiological shelf-life of the foodstuffs they produce and sell.

Lastly, Elior France is subject to Article 50 of the so-called "EGALIM" Act (French Act no. 2018-938 dated October 30, 2018) concerning balanced trade relations in the agricultural sector and access to healthy and sustainable food, which is referred to in the French Safety Agency's Technical Instruction DGAL/SDSSA/2019-555 dated July 30, 2019. This article incorporates one of the basic principles of Regulation (EC) no. 178/2002 in that it introduces a requirement for food operators to immediately inform the competent authorities if, based on their own risk assessment, they consider that a product may be injurious to human or animal health.

c) Italy

In Italy, the main regulatory authority for food safety is the Ministry of Health. Decree no. 123 dated March 3, 1993, transposing into Italian law the European Council Directive 89/397/EEC of June 14, 1989 on harmonizing the official control of foodstuffs in the European Union, covers all stages of the food industry: production, manufacture, processing, storage, transport, distribution and trade. It authorizes the performance of the following operations: inspections, sampling, laboratory analysis of samples taken, verification of staff hygiene, and a review of formal documentation and systems used by companies. Italian food safety regulations incorporate the standards provided for in EU legislation on food safety. (Regulation (EC) No. 852/2004, Regulation (EC) No. 2073/2005 - 1441/2007, Regulation (EC) No. 1935/2004 on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC, and subsequent amendments and additions).

Another major food safety regulation applicable in Italy is legislative decree 193, dated November 6, 2007, which entered into force on November 24, 2007 and concerns the implementation of Directive 2004/41/EC relating to safety controls on foodstuffs and the application of European Community regulations concerning such controls. This legislative decree sets out the sanctions that apply in the event of non-compliance with EU food safety regulations, notably regulations 852/2004 and 853/2004.

The other major food safety regulations applicable in Italy are Regulation no. 1169 of October 2011 relating to labeling, and legislative decree 231 of December 2017 concerning sanctions.

In addition to national and European-level food safety and hygiene regulations, the Group is subject to regional and provincial food safety obligations in Italy.

The main food safety supervisory bodies in Italy are:

    • The Ministry of Health, notably through programs set up by the food safety and nutrition department (Direzione generale per l'igiene e la sicurezza degli alimenti e la nutrizione).
    • The public health institute (Istituto Superiore di Sanità ).
  • The Italian police's food and drug control unit (Nuclei Antisofisticazione e Sanità (N.A.S.) dei Carabinieri), whose role is mainly to prevent and sanction.
    • The local health authorities (Aziende Sanitarie Locali) which have inspection powers.

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  • The government's veterinary services.
  • The Ministry of Agriculture (Ministero delle politiche agricole alimentari e forestali).

d)Spain

In Spain, the main food safety regulator is the Spanish Agency for Food Safety and Nutrition (Agencia Española de Seguridad Alimentaria y Nutrición, or the "AESAN"). The Group is subject to food safety regulations promulgated and enforced by the AESAN at national level, such as the General Health Act 14/1986, the Consumers and Users Protection Act 1/2007 and the Food Safety and Nutrition Act 17/2011.

As well as being required to hold specific authorizations to conduct business as a food operator in Spain, since the promulgation of Royal Decree 3484/2000 of December 2000 and Royal Decree 126/2015 of February 2015, the Group is also subject to specific hygiene rules for preparing pre-cooked meals as well as requirements to ensure that food handlers are supervised and instructed in food hygiene matters in a way that is commensurate with their professional activities. In addition to national food safety laws and regulations, the Group is also subject to specific obligations under local regulations applicable in the Spanish autonomous regions in which it operates.

e) United Kingdom

In the United Kingdom, the main food safety regulators are the Food Standards Agency (the FSA) for England, Wales and Northern Ireland, and Food Standards Scotland (FSS) for Scotland. The FSA and FSS are responsible for food safety and food hygiene across the United Kingdom. They work with local authorities to enforce food safety regulations and inspect meat plants to check compliance with the applicable regulations. The FSA also commissions research related to food safety. Key laws applying to food safety and hygiene in the UK include the General Food Law Regulation (EC) 178/2002 as well as the Food Safety Act of 1990 and Northern Ireland's Food Safety Order of 1991, as amended to bring them into line with the EU General Food Law.

The four countries of the United Kingdom have their own statutory rules which are detailed in:

  • The Food Safety and Hygiene (England) Regulations 2013.
  • The Food Safety and Hygiene (Scotland) (Amendment) Regulations 2012.
  • The Food Hygiene (Wales) (Amendment) Regulations 2012.
  • The Food Hygiene (Northern Ireland) Regulations 2006.

In conjunction with the legislation, the FSA writes guidance when there is a significant risk to food safety within the UK.

In the United Kingdom, the FSA, FSS and local authorities work in partnership to operate three food safety rating schemes: The Food Hygiene Rating System (FHRS) in England and Northern Ireland, the Food Hygiene Rating Act (Wales) 2013 and the Food Hygiene Information Scheme (FHIS) in Scotland. Within the UK, there is a statutory scheme called Primary Authority - established by the Regulatory Enforcement and Sanctions Act 2008 - which allows an eligible business to form a legally recognized partnership with a single local authority in relation to regulatory compliance. Elior UK has a direct partnership with Cheshire East Council, which acts as the company's Primary Authority, giving it authorizations and advice in relation to its management systems for food safety, hygiene and other safety issues.

f) United States

In the United States, food safety regulations are promulgated at the federal, state and local level. State and local agencies issue the regulations to be applied by restaurants and other catering establishments located within their jurisdiction. The US Food and Drug Administration (FDA) publishes the Food Code, a model that assists food control jurisdictions at all levels of government by providing them with a scientifically sound technical and legal basis for regulating food safety within the food services industry. Most States use the FDA Food Code as a model to develop or update their own food safety rules and to be consistent with national food regulatory policy. The FDA regulates all foods and food ingredients introduced into or offered for sale in interstate commerce, with the exception of meat, poultry, and certain processed egg products, which are regulated by the US Department of Agriculture.

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For the Group's US operations, hygiene and food safety are principally governed by local and federal rules and regulations. These rules and regulations are adopted by the FDA by way of Title 21 of the Code of Federal Regulations (CFR).

The Group's regulatory compliance measures in the United States include:

  1. Outsourcing food safety and hygiene audits to an approved independent organization.
  2. Pest management.
  3. Using the services of an independent inspection company.
  4. Using "safety information sheets" drawn up by a specialized chemical safety services firm.
  5. Commissioning an accredited laboratory to carry out tests on meals served.

All of the Group's distributors and suppliers are authorized and approved by local and state regulatory bodies and comply with the 2013 Food Safety Modernization Act (FSMA).

All of the Group's food managers are required to follow a food safety training course and to obtain food manager certification, which needs to be renewed every five years.

The Group operates in 48 different US States, which each have their own food hygiene rules and regulations.

As well as its catering activities, Elior North America has food production and processing operations which must be compliant with HACCP (Hazard and Critical Control Points) and HARPC (Hazard Analysis and Risk-based Preventive Controls) rules.

g) India

In India, food safety regulations are promulgated at federal and state level. At federal level, the main food safety agency is the Food Safety and Standards Authority of India (the FSSAI). The FSSAI regulates all foods proposed for sale, including dairy products and products containing poultry. It also certifies all commercialized food ingredients and products and each operator and vendor must have FSSAI certification, which is renewed annually following a detailed inspection. A state-level liaison officer regularly verifies that the applicable regulations and requirements are complied with. In addition, a regulatory authority carries out compliance inspections at regular intervals, and all operators have to follow a certified food safety training program and have a supervisor who has received training under the Food Safety Training and Certification (FoSTAC) program.

Elior India only deals with suppliers which are FSSAI certified and uses an independent national company for performing prevention checks.

1.7.6.1.2 Food labeling

Prepacked food that the Group sells must comply with European Union labeling requirements, notably European Directive 2000/13/EC of March 20, 2000 relating to the labeling, presentation and advertising of foodstuffs.

The applicable EU Law on the provision of food information to consumers was consolidated and updated by EU Regulation 1169/2011 of October 25, 2011, which has been effective since December 13, 2014. This Regulation makes a distinction between the information that must be given for prepacked food and non-prepacked food, and provides for harmonized and compulsory nutritional information labeling for prepacked food effective December 2016. In its catering activities, the Group is required to provide information on whether its food contains any of the 14 major allergens set out in Annex II of this Regulation.

Other EU regulations concerning food labeling include Regulation (EC) No. 1379/2013, which amends the labeling requirements for fishery and aquaculture products, and Regulation (EC) No. 1337/2013, which amends the labeling requirements for meat from pigs, sheep, poultry and goats.

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Local and national authorities may also introduce specific regulations or decrees clarifying particular points in the European regulations.

For example:

In France, the implementing decree 2015/447 dated April 17, 2015 - which has been effective since July 1, 2015 - clarifies the procedures for applying Regulation (EC) No. 1169/2011; decree no. 2002-1465 has regulated the labeling of beef in catering establishments since December 17, 2002; and the government order dated May 5, 2017 sets out the conditions for labeling manufactured nanomaterials in foodstuffs.

In Italy, several documents have been published relating to Regulation (EC) No. 1169/2011, including two memoranda issued by:

  • the Ministry of Health on February 6, 2015 related to information on the presence of allergens in food and beverages; and
  • the Ministry of Health/Ministry of Economic Development on November 16, 2016 related to foodstuffs that are not subject to nutritional disclosure requirements.

The Italian government has also issued a Legislative Decree related to EC Regulation No. 1169/2011 (decree No. 231 dated December 15, 2017, which came into force on May 9, 2018): "Sanctions applicable in the event of a breach of Regulation (EC) No. 1669/2011 on the provision of food information to consumers, and alignment of national legislation with Regulation (EC) No. 1669/2011 and Directive 2011/91/EU, in accordance with Article 5 of Act no 170-2015 dated August 12, 2016 on European delegation".

These provisions are in line with the following standards of the Codex Alimentarius international food safety standards:

  • CODEX STAN 1-1985(Rev.1-1991), Codex General Standard for the Labelling of Prepackaged Foods, and the subsequent amendments thereto.
  • CAC/GL 1-1979 (Rev. 1-1991), General Guidelines on Claims, and the subsequent amendments thereto.
  • CAC/GL 2-1985 (Rev. 1-1993), Guidelines on Nutrition Labeling, and the subsequent amendments thereto.
  • CAC/GL 23-1997 (Rev. 1-2004), Guidelines for Use of Nutrition and Health Claims, and the subsequent amendments thereto.

In Spain, food labeling is governed at national level by Royal Decree 126/2015, which sets out disclosure requirements concerning ready-to-eat,non-prepacked food.

In the United States, food labeling is generally regulated by the US Department of Agriculture (USDA), the Food and Drug Administration (FDA) and the Federal Trade Commission (FTC).

The Federal Food, Drug and Cosmetic Act (FFDCA) prohibits false and misleading labeling and sets out the labeling requirements for processed and prepacked food.

Prepacked food provided in locations where food is "served for immediate consumption", such as catering establishments, hospitals, schools, cafeterias, bakeries, etc., must comply with sections 101.1 et seq. of Title 21 of the Code of Federal Regulations (21 CFR) which state that labels must show the common name of the food item, its ingredients, the name/place of sale, its net quantity and its nutrition claims. In addition, any potential presence of the main food allergens must be stated on the labels (and any other forms of display).

Since May 7, 2018, restaurants and similar retail food establishments that are part of a chain with 20 or more locations, doing business under the same name, and offering for sale substantially the same menu items have also been subject to "menu labeling regulations". These regulations state that such establishments have to provide calorie information for standard menu items and ensure that additional nutrition information is available on request.

1.7.6.1.3 Other food service-related

regulations

In recent years, a number of national and local authorities have introduced specific regulations motivated by concerns about public health and environmental protection. These regulations cover, among other things, enhanced nutritional information for foodstuffs, requirements to use recyclable packaging, and additional taxes on food and beverages with high sugar content.

Additionally, the Group's operations in the education sector can be subject to specific regulations concerning the nutritional quality of meals served in school restaurants. This is notably the case in France (Decree 2011--1227 of September 30, 2011). Pursuant to this decree, the Group has a number of obligations it is required to respect in relation to drawing up menus for restaurants in state-run and private schools, in accordance with the recommendations set out in the French National Nutrition and Health Program

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(Programme National Nutrition Santé) and those issued by the GEMRCEN (a French governmental think-tankspecialized in nutritional issues in the contract catering industry).

New food service-related regulations were introduced in France in 2020: Act 2020-105 dated February 10, 2020 concerning the fight against waste and for a circular economy, which includes anti-food waste provisions and provides for ending the sale of single-use plastic packaging; and the related Decree (no. 2020-731 dated June 15, 2020) relating to the VAT exemption on donations of unsold goods to state-recognized social charities.

Restaurant facilities are also subject to regulations promulgated by national, regional and local authorities covering a wide range of matters such as the utilization and maintenance of restaurant sites and equipment and waste storage and disposal.

In addition, for catering sites or points of sale at which the Group serves alcohol, it is required to obtain liquor licenses and is subject to ongoing alcoholic beverage control obligations. Elior UK has developed tailored learning programs to teach its employees about the legislation related to serving alcohol, and in Scotland all employees who handle and serve alcohol are required to follow a two-hour training course beforehand.

In Portugal, Decree Law no. 10/2015 dated January 16, 2015 approved the legal framework for (i) accessing and exercising trade activities and food and beverage services and (ii) accessing trade, services and catering activities (RJACSR).

The Group is also required to comply with anti-smoking laws prohibiting smoking at dining establishments, such as the laws applicable in France since January 1, 2008 and in Italy since January 10, 2005 (Law no. 3/2003 dated January 16, 2003).

1.7.6.2 Labor and employment laws and regulations

In general, labor and employment laws and regulations have a significant impact on the Group's operations because of its large headcount, which, at September 30, 2020, comprised 105,000 employees. The Group is particularly affected by French legislation due to the high proportion of its employees based in France (over 40%).

Specific context of the Covid-19 crisis

In all of the Group's host countries, the Covid-19 crisis has led to changes in the regulatory framework in two main areas: (i) health and safety protocols to protect employees, guests and clients, and (ii) measures to adapt resources to business volumes in order to limit the impact of the crisis to the extent possible.

The regulatory framework evolved rapidly in 2019-2020 as the crisis advanced and as governmental decisions were taken. The fast-moving changes required all of our teams to be highly reactive and adaptable, not only in the sectors that were initially heavily impacted by reduced activity (Business & Industry and Education) but also in sectors that were stretched for resources, such as Health & Welfare.

In each of its operating countries, the Group implemented all of the measures it could to adjust its resources and organization to the situation. In particular, employees were asked to take paid vacation, internal mobility was encouraged, and short-time working and furlough programs were used.

The Group was often one step ahead concerning health and safety protocols, advising its clients how to define and implement them, which meant it could provide a continuity of service that matched their needs.

A description of the general types of labor and employment laws and regulations that affect the Group's operations is provided below.

1.7.6.2.1 Laws and regulations governing employment contracts

In most of the countries in which the Group operates, the traditional model of employment law is based on an employment contract signed between the employer and employee before or at the time the employee is hired. Fundamentally, the employment contract defines the employee's and employer's responsibilities, sets out the wage to be paid to the employee in return for his or her services, establishes the employee's working time and is entered into for an indefinite or pre-determined duration. Many features of employment contracts are subject to mandatory provisions of labor laws and regulations as well as to the provisions of collective bargaining agreements.

46 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

1.7.6.2.2 Collective bargaining agreements

Under French, Spanish and Italian law, the employer- employee relationship is not only regulated by applicable legislation and the employment contract executed between both parties, but also by industry-wide collective bargaining agreements ("CBAs"). CBAs may exist at national, regional or local level or be specific to a particular company. CBAs are agreements entered into between one or several trade union organizations representing employees, on the one hand, and an employer, or group of employers, on the other hand. National labor laws and CBAs constitute important sources of obligations relating to working conditions and govern the individual and collective relationships between employers and employees for the relevant industry. CBAs typically address (with respect to individual employees) matters such as working conditions and employment- related benefits, pay scales (with an industry specific minimum wage), working time, sickness and maternity leave, professional training, paid vacation, social welfare coverage and retirement fund contributions, year-end bonuses and financial terms of dismissals or retirement.

The scope of each national CBA is defined by reference to a given industry or type of business. Therefore, the applicable CBA for a company depends its principal business activity. Owing to the broad range of the Group's services, from diverse catering services to facility management services, it is subject to several different CBAs. As the terms of CBAs can vary significantly from one activity to another, within the same country the Group may have different responsibilities towards different categories of employees based on the business in which they operate.

All CBAs provide for a minimum wage that varies according to the classification of employees and the applicable pay scale. However, the wage of an employee cannot be below the statutory minimum wage that is set for all employees, regardless of classification, at national level. Trade unions renegotiate the terms of the industry- wide CBAs almost every year, including the terms of any increase in the minimum wage for each employee category. Companies to which the CBAs apply have an obligation to comply with these provisions by granting at least a corresponding salary increase every year, failing which employees may make legal claims for the enforcement of the industry-wide CBAs, back pay and damages.

The Elior Group 1

The Group's Businesses and Strategies

In France, employers may also enter into company-wide CBAs to address specific matters such as working time, salary levels, and welfare benefits.

1.7.6.2.3 Part-time and temporary work

At September 30, 2020, almost half of the Group's staff were employed on a part-time basis. Part-time employment is subject to specific laws and regulations in some of the countries where the Group operates. For example, under French law, part-time employment contracts must include certain mandatory provisions, such as the number of hours worked per week or per month, the arrangements for communicating the scheduling of hours worked per week or per month, and the maximum number of overtime hours that the employee can work per month. If a company is found not to be in compliance with regulations on part-time employment, the employee concerned may seek to reclassify his or her part-time employment contract as a full-time employment contract, and may also claim back pay and damages.

The Group is likewise restricted in the manner in which it may hire temporary workers. For example, under French law, an employer wishing to take on non-permanent workers may either hire an employee under a fixed-term employment contract or take on a temporary worker through an agency. The use of fixed-term employment contracts/temporary workers must be restricted to the performance of clearly defined and temporary tasks in specific circumstances provided by law (e.g., (i) to replace an employee on a temporary leave of absence or whose employment contract is suspended, (ii) to temporarily fill a position before an employee can be hired under a permanent employment contract or, after a permanent employee has left, before the position is eliminated, or (iii) to cover a temporary increase in the company's business). In particular, the Group may not use fixed-term employment contracts/temporary workers to fill a post on a long-term basis in connection with its ordinary and ongoing business.

1.7.6.2.4 Employee representation

a) Right to representation and trade unions

In the majority of the countries in which the Group operates, its employees have the legal right to elect representatives from among their ranks to act as a liaison between the workforce and management. Such employee representatives are responsible for presenting to the employer all requests and grievances from employees, notably regarding compensation and compliance with applicable labor laws and CBAs. The employer is required to regularly provide the employee representatives with information regarding various matters such as working

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conditions and the company's financial situation. Depending on the country, employee representatives may also be responsible for notifying the relevant labor regulation enforcement authority of any claims or grievances from employees related to a breach of labor laws or regulations. Employers may also be exposed to the risk of strikes and work stoppages.

In addition, employees may choose to join a trade union to represent their interests. Depending on the country concerned and the size of any given worksite, the Group may be obliged to recognize the trade union and allow employees to unionize. In certain countries, such as France, there is a limited number of nationally-recognized trade unions that are given the legal authority to negotiate national and company-specific CBAs.

b)Works councils - Employee representative bodies

In accordance with EU law, the Group has a European works council in place that serves as a forum for employee representatives to engage in direct discussions with members of Group management. EU law requires any company that has (i) subsidiaries in at least two different EU member states, (ii) at least 1,000 employees in EU or EEA member states, and (iii) a minimum of 150 employees in at least two EU member states, to set up a European works council (an "EWC"). EWCs bring together employee representatives from the different European countries in which a multinational company has operations. During EWC meetings, employee representatives are informed and/or consulted by Group management on transnational issues that concern the Group's employees.

  1. National labor laws in most of the countries in which the Group operates also require the establishment of a local Social and Economic Committee ("SEC") The frequency of SEC meetings, the amount of information that must be provided to its members, and how SEC opinions must be taken into account vary from country to country. In France, certain employer decisions relating to issues such as workforce reductions or changes in the legal and/or financial organization of the company (in particular in the case of a merger or a sale of assets or shares) require a prior information and/or consultation process to be carried out with the relevant SECs (local and/or central and/or European). In such cases, no final decision may be taken before the relevant employee representative body has delivered its formal opinion (whether negative or positive) on the proposed decision.

c) Employee representation on corporate boards

In France, employees may be represented on their company's Board of Directors (or Supervisory Board where applicable). Companies that for the past two consecutive fiscal years have had either (i) 1,000 permanent employees or more on their payroll who work for the company or its direct or indirect subsidiaries with registered offices located in France, or (ii) 5,000 permanent employees or more worldwide who work for the company or its direct or indirect subsidiaries with registered offices located in France and abroad, must appoint at least one - and in certain cases - two Board members representing employees.

Article L. 22-10-7 of the French Commercial Code provides that a holding company whose principal activity is to acquire and manage subsidiaries and affiliates is not subject to this requirement concerning employee representation on its board, if it meets both of the following criteria:

  • It is not required to put in place a social and economic committee pursuant to Article L. 2311-2 of the French Labor Code.
  • It owns, either directly or indirectly, one or more subsidiaries that are subject to the above requirement.
  • Its shares are not traded on a regulated market or at least four-fifths of its shares are held, directly or indirectly, by one person or legal entity, acting alone or in concert.

Consequently, in accordance with the French Commercial Code, at the Annual General Meeting of March 20, 2020, the shareholders approved amendments to the Company's bylaws providing for the appointment of two employee representative members of the Board of Directors.

In addition, for companies whose shares are traded on a regulated market, if at the close of the last fiscal year employees held more than 3% of the share capital, the company's shareholders must appoint one or more employees to the Board of Directors or the Supervisory Board to represent employee shareholders, who are put forward by the shareholders referred to in Article L. 225- 102 of the French Commercial Code.

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d)Workplace health and safety

The Group is also subject to regulations related to employees' health and safety in the workplace. Such regulations may require companies to put in place operational procedures to ensure that their working practices are safe and to reduce potential workplace hazards.

Occupational health and safety matters are regulated and enforced by a variety of authorities, including the European Agency for Safety and Health at Work, the French Directions régionales des entreprises, de la concurrence, de la consommation, du travail et de l'emploi (regional directorates of companies, competition, consumption, labor and employment), the UK Health & Safety Executive, and the US Occupational Safety and Health Agency.

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1.8 ELIOR GROUP ON THE STOCK MARKET

1.8.1 FINANCIAL COMMUNICATIONS AND SHAREHOLDER RELATIONS

1.8.1.1 Preparation of financial communications

The Chief Executive Officer and the Chief Financial Officer are responsible for the Group's financial communications.

In application of the Board of Directors' Rules of Procedure, any key data due to be released to the market and any major press releases must be approved in advance by the Board of Directors.

1.8.1.2 Financial communications policy

The Chief Executive Officer, Chief Financial Officer, and the Head of Investor Relations are the Company's sole spokespeople for financial communications.

Information is released either before the opening or after the close of trading on Euronext Paris so as not to influence the share price.

In order to respect the principle of fair access to information, press releases are issued simultaneously to the whole of the financial community and the market authorities.

Additionally, for the purpose of transparency and in accordance with the applicable regulations, Elior Group has drawn up a directors' charter as well as a code of conduct applicable to its directors, officers and employees. These documents cover the procedures to adopt concerning privileged information to prevent conflicts of interest and avoid risks related to insider trading.

1.8.1.3 Regular contacts with

shareholders and investors

Elior Group regularly organizes meetings during the year to keep communication channels open at all times with shareholders and the financial community at large. A financial calendar setting out the Company's publications and events for the financial community is available on the Elior Group website.

On May 27, 2020, the Chief Executive Officer and Chief Financial Officer held a conference call during which they presented the Group's results for the first half of fiscal 2019-2020 and answered questions from the financial community.

On November 25, 2020, the Chief Executive Officer and Chief Financial Officer held a conference call during which they presented the Group's results for fiscal 2019-2020 and answered questions from the financial community

The Annual General Meeting is an excellent forum for the Company to exchange information directly with its shareholders. Official notice of the meetings is published in the press and in the French official legal journal (BALO). The Annual General Meeting pack is available on the Elior Group website at least 21 days before the Meeting takes place and is sent to shareholders on request.

The Chief Executive Officer, Chief Financial Officer and Head of Investor Relations regularly participate in roadshows and investor meetings in order to maintain a regular dialog with the financial community.

All of the Group's directors, officers and employees have a duty of confidentiality and discretion.

The Group's risk prevention measures related to financial information are described in Chapter 3, Section 3.2 of this Universal Registration Document.

1.8.1.4 A steady flow of information

In order to ensure information transparency, a "Finance" section is available on the Elior Group website, which enables shareholders, analysts and investors to access at any time all the information required under the applicable regulations. The website serves as a database of the Group's main financial communications and allows investors to keep up to date in real time. The documents available on the website include the Company's Bylaws, the Board of Directors' Rules of Procedure, financial publications calendar, press releases, and financial reports.

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Elior Group on the Stock Market

The Elior Group share price is also shown in real time.

All of the Group's statutory documents are available at the Company's headquarters.

Provisional financial calendar for fiscal 2020-2021

The Universal Registration Document as filed with the AMF is posted on both the Elior Group and AMF websites, in French and English.

Thursday, January 28, 2021

Release of first-quarter fiscal 2020-2021 revenue figures

Friday, February 26, 2021

2021 Annual General Meeting

Wednesday, May 20, 2021

Release of first-half fiscal 2020-2021 results

Wednesday, July 28, 2021

Release of third-quarter fiscal 2020-2021 revenue figures

Wednesday, November 24, 2021

Release of full-year fiscal 2020-2021 results

Any changes to this provisional calendar will be posted on

Elior Group's website.

Investor Relations Department

+33 (0)1 71 06 70 08

investor@eliorgroup.com

Registered shares

Elior Group's shares are managed by BNP Paribas Securities Services, which can be contacted at the following address:

BNP Paribas Securities Services

Grands Moulins de Pantin

9 rue du Débarcadère

93761 Pantin Cedex, France

Phone: +33 (0)1 57 43 02 30 - open Monday through Friday from 8:45 a.m. to 6:00 p.m. (CET - Paris time)

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1.8.2 THE ELIOR GROUP SHARE

Elior Group's shares have been listed on Euronext Paris (Compartment A) since June 11, 2014 under ISIN FR0011950732. Their initial listing price on June 11, 2014 was €14.75 per share.

On March 6, 2015, Elior Group announced that the authority responsible for the various indices of Euronext Paris - the Conseil Scientifique des Indices Euronext Paris - decided to include the Company's shares in the SBF 120 index as from the close of trading on March 20, 2015.

At December 30, 2016, Elior Group's closing share price was €21.72. At December 29, 2017, Elior Group's closing share price was €17.23. At December 28, 2018, Elior Group's closing share price was €13.06. At December 31, 2019, Elior Group's closing share price was €13.10.

At December 31, 2020, Elior Group's closing share price was €5.52.

Elior Group's share performance since the IPO:

Date

Trading volume

End-of-month

Monthly high

Monthly low

share price (in €)

(in €)

(in €)

June 20141

16,959,901

14.83

15.90

14.35

July 2014

3,385,985

14.25

15.30

13.82

August 2014

1,556,537

12.90

14.48

12.41

September 2014

1,943,224

12.92

14.00

12.30

October 2014

2,097,232

12.20

13.13

11.54

November 2014

2,662,405

12.60

13.23

12.26

December 2014

3,225,981

12.30

13.60

11.80

January 2015

3,110,181

13.99

14.50

11.99

February 2015

1,659,455

14.84

14.85

14.04

March 2015

4,038,437

15.99

17.24

14.53

April 2015

3,727,468

16.75

16.92

15.63

May 2015

5,143,079

16.61

17.58

15.48

June 2015

4,907,967

17.97

19.04

16.83

July 2015

3,219,321

17.92

19.84

17.55

August 2015

2,185,856

18.11

18.98

16.52

September 2015

3,328,863

17.10

18.48

16.55

October 2015

4,659,420

17.27

18.03

16.40

November 2015

3,559,746

18.30

18.38

16.55

December 2015

4,960,716

19.30

19.45

17.26

January 2016

5,749,046

18.52

19.28

17.15

February 2016

4,195,169

18.70

18.78

16.65

March 2016

17,787,296

19.27

19.79

18.13

April 2016

5,080,226

18.78

19.48

18.50

May 2016

4,592,084

20.17

20.45

18.22

June 2016

6,808,171

19.63

20.70

18.45

July 2016

5,969,994

19.53

20.28

19.02

August 2016

4,145,441

20.56

20.98

19.29

September 2016

4,127,986

20.38

21.09

20.11

October 2016

3,542,647

20.46

21.00

20.21

November 2016

5,501,429

19.58

20.55

17.90

  • From June 11, 2014 (the initial listing date of the Company's shares)

52 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

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Date

Trading volume

End-of-month

Monthly high

Monthly low

share price (in €)

(in €)

(in €)

December 2016

5,772,438

21.72

21.80

18.54

January 2017

4,667,899

20.70

22.11

20.48

February 2017

4,712,714

21.19

21.60

20.67

March 2017

5,045,756

21.27

21.64

20.30

April 2017

6,174,649

22.90

23.12

21.29

May 2017

5,329,098

25.22

25.48

22.92

June 2017

6,936,726

25.44

26.06

24.83

July 2017

8,447,005

22.42

25.87

21.41

August 2017

5,634,454

22.30

23.22

22.03

September 2017

7,107,760

22.40

23.38

22.15

October 2017

6,440,471

24.38

24.42

22.34

November 2017

11,271,362

18.46

24.85

18.17

December 2017

15,640,013

17.23

18.95

15.95

January 2018

10,532,196

18.56

19.71

17.07

February 2018

7,001,194

18.02

18.80

17.54

March 2018

7,205,688

17.66

19.08

16.63

April 2018

6,534,858

16.93

17.58

16.10

May 2018

16,295,847

14.24

17.11

12.52

June 2018

18,219,953

12.36

15.37

11.59

July 2018

8,201,745

14.00

14.67

11.81

August 2018

5,455,600

13.49

14.60

13.33

September 2018

5,887,464

13.34

13.69

12.39

October 2018

7,218,308

12.73

13.62

11.26

November 2018

7,715,313

13.11

13.68

12.31

December 2018

9,170,914

13.06

13.39

11.30

January 2019

9,686,102

12.30

13.74

12.13

February 2019

5,812,262

12.68

13.1

11.91

March 2019

8,412,020

11.93

13.64

11.77

April 2019

6,174,949

12.34

13.06

11.86

May 2019

11,096,300

10.51

12.37

9.605

June 2019

10,145,697

12.09

12.25

10.28

July 2019

8,599,702

11.83

12.33

11.03

August 2019

7,406,694

11.58

11.97

10.94

September 2019

5,344,045

12.19

12.73

11.59

October 2019

4,668,392

11.59

12.23

11.27

November 2019

4,943,267

11.62

12.33

11.31

December 2019

7,728,855

13.10

13.33

10.87

January 2020

8,080,000

12.06

13.16

11.89

February 2020

7,150,000

10.82

12.86

10.61

March 2020

20,700,000

5.72

11.09

3.88

April 2020

10,640,000

6.04

7.20

5.08

May 2020

13,850,000

5.53

6.75

4.80

June 2020

23,880,000

5.07

7.88

5.00

July 2020

16,680,000

4.69

5.47

4.66

August 2020

10,090,000

4.92

5.45

4.43

September 2020

17,500,000

3.96

5.14

3.77

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 53

  • The Elior Group

Elior Group on the Stock Market

Date

October 2020

November 2020

December 2020

Trading volume

16,810,000

37,350,000

18,940,000

End-of-month

Monthly high

Monthly low

share price (in €)

(in €)

(in €)

3.24

4.11

3.06

4.80

5.85

3.16

5.52

5.98

4.71

The above information was extracted from the Finance section of Elior Group's website at www.eliorgroup.com

Per-share data

Year ended

September 30, 2020

Weighted average number of shares (in millions)

174

Attributable net profit/(loss) (in € millions)

(483)

Earnings/(loss) per share (in €)

(2.78)

Net dividend per share (in €)

-

54 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

.2

CORPORATE SOCIAL RESPONSIBILITY

2.1 Corporate social responsibility: a value-creation

driver

56

2.1.1

Four pillars of responsibility

57

2.1.2

CSR governance

59

2.1.3

Non-financial risk map

60

2.2

Conducting business responsibly

62

2.2.1

The Elior Group ethical principles

62

2.2.2

Fighting corruption

62

2.2.3

Duty of vigilance

64

2.3 Promoting a tasty, healthy and sustainable

diet

66

2.3.1 Designing great teasting, healthy and sustainable

offerings

66

2.3.2 Promoting good eating habits

68

2.3.3 Guaranteeing the highest food quality and safety

levels

69

2.4

Responsible procurement

72

2.4.1 Prioritizing products from sustainable

agriculture

72

2.4.2 Eliminating products from the supply chain that

contribute to deforestation

74

2.4.3 Promoting the use of responsible packaging and

consumables

75

2.5

A circular model

76

2.5.1

Reducing food waste

76

2.5.2 Minimizing the Group's environmental

footprint.77

2.6 Ensuring employees' health, safety and

development

81

2.6.1

Employee data

81

2.6.2

Guaranteeing employee health and safety

82

2.6.3 Building employee skillsets and encouraging

internal mobility and career development

83

2.6.4

Promoting diversity and inclusion

84

2.6.5

Labor relations and compensation policy

85

2.6.6

Having a positive impact on local communities 86

2.7

Methodological note

87

2.7.1

Non-financial reporting process

87

2.7.2 Cross-reference table - Non-financial performance

statement (NFPS)

90

2.7.3 Summary of environmental and social

indicators

91

2.7.4 Summary of HR indicators

92

2.7.5 Report by the independent third party on the consolidated non-financial performance

statement in the management report

95

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 55

  • Corporate Social Responsibility

Corporate Social Responsibility: A Value-Creation Driver

2. CORPORATE SOCIAL RESPONSIBILITY

2.1 CORPORATE SOCIAL RESPONSIBILITY: A VALUE-

CREATION DRIVER1

With operations in six main countries, the Elior group has more than 105,000 employees who work dedicatedly every day to feeding four million people in 22,700 restaurants in the Education, Business & Industry and Healthcare & Welfare markets. The Group also takes care of 2,300 sites for its clients.

We are deeply committed to the health and well-being of all our guests, the development of all our employees, and the environmental impact of all our businesses. This commitment is clear in the strategy and action plans we have put in place for Corporate Social Responsibility (CSR) for over ten years now. As a signatory of the UN Global

Compact since 2004, we firmly believe that our responsibility extends beyond the direct impacts of our business and that we must make a positive contribution to our ecosystem right across our value chain.

We have kept our promise to place sustainable development at the heart of our corporate strategy, as proved by the launch in 2016 of our CSR strategy called "The Elior Group Positive Foodprint Plan2". In 2019-2020, Elior generated €4 billion in revenue and this value was shared between its various stakeholders (employees, suppliers, government agencies, shareholders and lenders) as shown in the diagram below.

  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2 Referred to as the Positive Foodprint Plan in the rest of this document.

56 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Corporate Social Responsibility: A Value-Creation Driver

"The launch of the New Elior plan once again demonstrates the Group's objective of putting corporate social responsibility at the heart of everything it does. By publishing this Universal Registration Document and qualifying this CSR chapter as an Advanced-level Communication on Progress (COP), I am pleased to reaffirm our commitment to respecting and promoting the ten fundamental principles of the United Nations Global Compact1 and to ensuring that these principles will continue to play a central role in the Group's organization and corporate strategy."

Philippe Guillemot, Chief Executive Officer of Elior Group

In June 2019, Philippe Guillemot, Elior's Chief Executive Officer, presented the Group's new strategic plan, called New Elior. Covering the years up to 2024, this plan prioritizes the strong local roots of the Group's contract catering and services activities (see Chapter 1, Section 1.7.3, "The Group's Competitive Strengths"). It also reiterates the central role that sustainable development plays in our everyday work and actions in order to create long-term value not just for the Group but also for all of its stakeholders.

After a good start to fiscal 2019-2020, our Education and Business & Industry markets were hit hard by the lockdown measures put in place in the countries where we

operate as well as by an increase in home-working. In response to this unprecedented situation, we have accelerated our transformation process and reaffirm the goals of our New Elior 2024 strategic plan, including the key objective of actioning our CSR priorities across all of our operations. As explained in Chapter 1, Section 1.3.1.3, "Market Trends", this crisis period has also confirmed the importance of our business fundamentals concerning community catering, safety, and food hygiene. It has encouraged us to go even further in focusing on the added value of our offerings in order guarantee the well-being of our guests and respect the environment while providing dining experiences to savor.

2.1.1 FOUR PILLARS OF RESPONSIBILITY

Elior has built its Positive Foodprint strategy around four pillars of responsibility, which were identified based on a materiality analysis performed in 2015:

  • Healthy Choices
  • Sustainable Ingredients
  • Circular Model
  • Thriving People and Local Communities

The relevance of these four priority areas was confirmed by the results of the non-financial risk mapping process carried out in 2018 and then updated in 2019 and 2020 (see Section 2.1.3 below, "Non-Financial Risk Map"). In 2019, the Group revised its Positive Foodprint objectives as well as its CSR governance methods (see Section 2.1.2 below, "CSR Governance").

As stated above, due to the Covid-19 crisis, we have accelerated the rollout of our New Elior strategy - including the Positive Foodprint Plan - across all of our operations. Not least because sustainability is central to dealing with the current situation. And by building supply chains focused on safety, security and value we are making our Group more resilient to international crises.

Restated goals

We have defined the objectives for the priority areas set in the Positive Foodprint Plan in order to align them as closely as possible with the reality of our operations. Performance indicators have been put in place to guide the Group's action plans and assess the progress made (see table below).

  • Further information about the ten principles of the United Nations Global Compact and the disclosures required in an Advanced -level COP are available on the Global Compact website at www.unglobalcompact.org

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 57

  • Corporate Social Responsibility

Corporate Social Responsibility: A Value-Creation Driver

As a passionate campaigner for the transition to better food habits, we seek to transparently measure and constantly improve the value of our meals in terms of their impact on society, people and the environment. We endeavor to achieve this through offerings that:

financial performance indicators when it releases its quarterly financial results. This means that all of its stakeholders can follow developments in the Group's non- financial performance.

  • Are healthy and provide guests with transparent nutritional information as well as a wide choice of vegetarian options.
  • Respect the environment, with a focus on certified sustainable supplies and measures to reduce food waste.
  • Give people enjoyable dining experiences, by carrying out satisfaction surveys and being a "chef-centric" group.

In order to meet these objectives, each Elior Group subsidiary puts in place action plans and develops systems and processes to effectively address the challenges and restrictions of its particular market.

Stronger oversight

The Group assesses all of its non-financial indicators once a year. For some of the Positive Foodprint Plan's key performance indicators, however, we have set up a quarterly tracking process. On an aggregate basis, the Group's non-financial performance indicators cover all of the geographic regions in it operates.

In addition, so as to give a straightforward and transparent overview of the Group's approach, Management has decided to report on some of these non-

Contributing to Sustainable Development Goals

The objectives in the Positive Foodprint Plan are aligned with the United Nations Sustainable Development Goals (SDGs). The Group has chosen to particularly focus on the four SDGs that directly relate to its operations, and particularly its catering business.

58 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Corporate Social Responsibility: A Value-Creation Driver

Positive Foodprint Plan

Sustainable Development Goals

Description of SDG

Healthy choices

SDG 3: "Good health and

Ensure healthy lives and promote well-being

well-being"

for all at all ages.

End hunger, achieve food security and

Sustainable ingredients

SDG 2: "Zero hunger"

improved nutrition and promote sustainable

agriculture.

SDG 12: "Responsible

Ensure sustainable consumption and

A circular model

consumption and

production patterns.

production"

Thriving people and

SDG 8: "Decent work and

local communities

economic growth"

Promote sustained, inclusive and sustainable economic growth, full and

productive employment and decent work for all.

2.1.2 CSR1 GOVERNANCE

In order to help achieve the objectives in our Positive Foodprint Plan, we have set up a specific CSR governance system. The underlying purpose of this system is for the Group to more effectively factor in its corporate social responsibility across its entire organization, from its management bodies through to its operations teams.

Group CSR Committee

Set up in 2019, the Group CSR Committee is chaired by Elior's Chief Executive Officer, Philippe Guillemot, and its permanent members include the people responsible for each of the Positive Foodprint Plan's priority areas at Group level: the Chief Procurement and Logistics Officer, the Chief Human Resources Officer and the CSR Officer. The Group Chief Communications Officer is also a permanent member of this Committee.

The Committee's role is to validate strategic decisions relating to the Positive Foodprint Plan's priority areas, monitor the Plan's developments and adjust its priorities in line with changes in the Group's operating environment. It meets at least four times a year and, depending on the matters being addressed, may invite other participants to attend, either from within or outside the Group.

Strategy, Investments and CSR Committee

Each year, the headway made by the Group in terms of the Positive Foodprint Plan's objectives is shared with the Board of Directors via the Strategy, Investments and CSR Committee. Comprising four members (see Chapter 3, Section 3.1.1 "Governance Structure"), this Committee advises the Board on strategic and investment decisions. It assesses the Group's CSR values and commitments and helps ensure they are effectively taken into account in the Board's decisions.

Network of CSR officers

The CSR officers are in charge of deploying the Positive Foodprint Plan's commitments in the Group's various operational entities. They are appointed by the entities' CEOs and are tasked with defining and implementing action plans adapted to their respective markets and businesses. In fiscal 2019-2020, 100% of the Group's consolidated revenue was covered by the network of CSR officers.

  • Corporate Social Responsibility

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 59

  • Corporate Social Responsibility

Corporate Social Responsibility: A Value-Creation Driver

2.1.3 NON-FINANCIAL RISK MAP

In 2015, Elior created a materiality matrix, which it then used in 2016 as the basis for its first non-financial risk map validated by the Group's governance bodies. A restricted risk universe was mapped out based on the Group's business sectors, geographic locations and main strategic goals, incorporating around twenty risks (identified via the materiality analysis) that could significantly impact the Group's business or its stakeholders. Out of this mapping process twelve main environmental, HR and social risks were identified.

In 2019-2020, we launched a project to integrate these twelve priority non-financial risks into our internal risk management system. This update to the non-financial risk map confirmed that the four pillars of the Positive Foodprint Plan are still highly relevant and did not

identify any new CSR risks. Nine of the twelve risks already formed part of the risks regularly monitored by the Group (see Chapter 3, Section 3.2, "Risk Management").

Two further risks have been added to the Group's risk management system: waste management and climate change & environmental pollution (a merger of two risks identified in 2018). The gross criticality of these risks will be assessed using an approach consistent with that applied by the Risk Management Department, based on two criteria: the level of impact if the risk occurs and the probability that the risk will occur. This gross criticality analysis will be supplemented in the future by an analysis of the risks' net criticality following the rollout of the multi-year audit plan (see Chapter 3, Section 3.2, "Risk Management").

Performance indicators (see

Non-financial risks

Integration into an existing

Risk management

Sections 2.7.3, "Summary of

identified in 2018-

risk in the risk management

environmental and social

policies

2019

system

indicators", and 2.7.4, "Summary

of HR indicators"

Number of information sessions given

about ethical business conduct

Unethical practices and

Supply chain and logistics

2.2 Conducting Business

Number of employees having

lack of transparency

Responsibly

participated in a training or awareness-

raising session about ethical business

conduct

Food safety and menu quality

% purchases of certified food produce

% purchases of local food produce

Failure to include CSR

% purchases of organic food produce

2.4 Responsible

% cage-free eggs

criteria in procurement

Procurement

% responsibly-sourced seafood

practices

% responsible packaging and

Supply chain and logistics

consumables used

Number of supplier audits performed

Food safety and menu quality

Failure to adapt to guests' new expectations

Loss of key contracts

% vegetarian recipes

2.3 Promoting a Tasty,

% consolidated revenue from entities

testing at least one nutritional

Healthy and Sustainable

information tool or system

Diet

Number of restaurants that carried out

at least one satisfaction survey

Poor hygiene and food

Food safety and menu quality

safety

Poor working

Changes in hygiene, health and

conditions

safety rules

Inequality and

Changes in legislation

discrimination

2.3 Promoting a Tasty, Healthy and Sustainable Diet

2.6 Ensuring Employees' Health, Safety and Development

2.6 Ensuring Employees' Health, Safety and Development

  • Number of hygiene audits performed
  • Number of product analyses performed
  • Number of supplier audits performed
  • Frequency rate of workplace accidents
  • Severity rate
  • Breakdown of workforce by gender
  • % of employees with a disability

60 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Corporate Social Responsibility: A Value-Creation Driver

Failure to attract and

Average seniority (permanent

retain talent

2.6 Ensuring Employees'

workforce)

Key personnel

Health, Safety and

% internal recruitment for managerial

Failure to include CSR

Development

posts

criteria in pay

structures

Failure to protect

Changes in hygiene, health and

2.6 Ensuring Employees'

Frequency rate of workplace accidents

employees' health and

Health, Safety and

safety rules

Severity rate

safety in the workplace

Development

% sites collecting organic waste for

Poor resource and

reuse/recycling

Waste management

2.5 A Circular Model

• % used cooking oils reused/recycled

waste management

% consolidated revenue from entities

testing solutions to reduce food waste

Water use

Environmental

Climate and pollution

2.5 A Circular Model

Electricity use

pollution (water, air)

Carbon footprint assessment (scopes

1, 2 & 3)

Water use

Poor use of water and

Climate and pollution

2.5 A Circular Model

Electricity use

energy

Carbon Footprint assessment (scopes

1, 2 & 3)

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 61

  • Corporate Social Responsibility

Conducting Business Responsibly

2.2 CONDUCTING BUSINESS RESPONSIBLY1

At Elior we make sure that all of our business activities are conducted in compliance with ethical principles and the applicable national laws and regulations. In France, since the introduction of the anti-corruption provisions of the "Sapin II" Act and the new Duty of Vigilance Act,

companies are required to set up structured systems for overseeing measures related to combating corruption, human rights breaches and environmental damage, as well as health and safety issues.

2.2.1 THE ELIOR GROUP ETHICAL PRINCIPLES

All Elior employees are required to comply with the laws and regulations in force in the countries in which we operate and must always respect the Group's Ethical Principles.

Issued in June 2016, the Elior Group Ethical Principles are aimed at creating a shared framework for all Group employees in their daily working lives. They are a clear illustration of our proactive strategy to support and promote the main international ethics standards and guidelines that we have adopted, namely:

  • The Universal Declaration of Human Rights.
  • The International Labour Organization's Declaration on Fundamental Principles and Rights at Work.
  • The United Nations Global Compact (see Section 2.1 above, "Corporate Social Responsibility: A Value-Creation Driver").
  • The United Nations Sustainable Development Goals (see Section 2.1 above, "Corporate Social Responsibility: A Value-Creation Driver").

These Ethical Principles have been rolled out to all of the Group's operating entities and are applied in accordance with local laws and regulations.

In order to be fully understood and taken on board by all of our people, the Elior Group Ethical Principles have been translated into five languages2. The French and English versions are available on the Group's corporate website at www.eliorgroup.com

2.2.2 FIGHTING CORRUPTION

As a member of the United Nations Global Compact, Elior upholds and promotes the fight against all forms of corruption. In 2019-2020, the proportion of the Group's revenue generated in countries that have a high risk of corruption based on Transparency International's Corruption Perceptions Index (score below 60/100) was just over 10%.

Overseen by the Chief Compliance Officer - a post created in September 2018 - the Group's anti-corruption system was strengthened in 2018-2019 following the entry into force on June 1, 2017 of the anti-corruption provisions contained in France's "Sapin II" Act on transparency, the prevention of corruption and the modernization of the economy3.

Risk mapping

The Group's corruption risks are assessed on an annual basis using a risk mapping procedure specifically targeting these issues (see Chapter 3, Section 3.2, "Risk Management"). In September 2019, we completed an update of this risk map, reducing the number of risks to 15 and revising their names and descriptions. In accordance with the applicable legal requirements, the update process was carried out in all of the Group's geographic regions using the Governance, Risk and Compliance (GRC) system and adjusting granularity on a case-by-case basis. A new mapping process for corruption risks is planned for the first half of 2020-2021.

  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2 The Elior Group Ethical Principles are available in French, English, Spanish, Portuguese and Italian.
    3 Elior Group and all of its subsidiaries (as defined in Article L 233-1 of the French Commercial Code) and the companies controlled by Elior Group (as defined in Article L 233-3 of said Code) are subject to the provisions of the Sapin II Act.

62 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Conducting Business Responsibly

Internal anti-corruption system

In order to facilitate employees' take-up of the Elior Group Ethical Principles, in the second half of 2018 the Group published an Integrity Guide. Available in five languages (French, English, Spanish, Italian and Portuguese), the aim of this guide is to provide clear rules as well as theoretical and practical information so that everyone can be compliant with the relevant laws and the Group's Ethical Principles. The document is split into five parts:

  1. Organizational and responsibility-related rules applicable within the Elior group concerning the prevention of corruption.
  2. Definitions of key corruption-related terms and concepts.
  3. Anti-corruptionrules.
  4. Practical recommendations.
  5. Practical information.

The Integrity Guide is supplemented by anti-corruption policies that explain how the general rules should be applied, especially for:

  • Gifts and invitations offered and received.
  • Relations with intermediaries.
  • Corporate sponsorship and philanthropy.
  • Conflicts of interest.

These policies are the same for the Group as a whole but may sometimes incorporate specific local factors.

The Group also has a whistle-blowing system, which has been in place since 2018. Accessible by email or telephone in all of Elior's countries of operation, this system enables employees to raise the alarm in the event of any breach of the Integrity Guide. A whistle-blowing charter specifying the terms and conditions for using the system has been published. Also available in five languages (French, English, Spanish, Italian and Portuguese), this charter guarantees that any information provided via the whistle- blowing system will remain strictly confidential at all times. The Group undertakes to protect whistle blowers from any negative consequences, provided they have acted in good faith and the information they give is based on verifiable facts.

Additionally, the Group has launched a website

specifically dedicated to integrity: https://integrity.eliorgroup.net Open to everyone and available in four languages (French, English, Spanish and Italian), this site sets out all of our integrity commitments as well as the corresponding documentation (Ethical Principles, Integrity Guide, the main anti-corruption policies specific to each company, and the whistle-blowing charter). It also offers explanatory videos and quizzes so that employees can test their own knowledge about integrity and their understanding of what the Group expects of them. This site was remodeled in January 2020, with new content added, including a video message from the Chief Executive Officer, Philippe Guillemot.

Employee training

In 2017-2018, all of our employees in France in charge of relations with public authorities were given training on the lobbying provisions contained in the French Sapin II Act.

In 2018-2019 and 2019-2020, we reinforced our anti- corruption awareness-raising program and gave training courses (mainly face-to-face) in nearly all of our host countries to over 1,000 employees identified as potentially exposed to situations of corruption. These employees - who were identified through the risk mapping process - were mainly members of the Group's regional management committees, purchasers, business developers, sales people, operations directors and regional directors. The training sessions are led by the Group's compliance teams. In 2019-2020, 24 information sessions on business ethics were held, with 247 employees participating. The plan was to extend this program to other employee categories but this was halted by the outbreak of the Covid-19 pandemic. However, during the pandemic we tried out remote training.

An online learning course open to all employees has also been launched in the United Kingdom, and we are currently looking into the possibility of extending it to our other host countries and all categories of employees.

Since October 1, 2020, in a number of the Group's host countries its employment contracts include a compliance clause which requires all new employees to visit the Group's dedicated integrity website and familiarize themselves with its policies on business ethics.

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 63

  • Corporate Social Responsibility

Conducting Business Responsibly

Fiscal responsibility

As a responsible enterprise, Elior believes that paying its taxes is a civic duty that helps to support the regions where it operates. We therefore make sure that all of our entities respect the applicable national and international tax rules and regulations and that they pay their taxes in each jurisdiction. Altogether, the Group paid €11.3 million in corporate income tax in 2019-2020.

In order to ensure that we are fully tax compliant, in 2018 we created a new post of Group Chief Tax Officer and drew up a tax policy which focuses in priority on combating tax evasion and has been relayed to all of the Group's operating entities. In addition, in accordance with the applicable regulatory requirements, the Group has performed a country-by-country reporting process, disclosing a breakdown of its earnings, income tax and operating activities by tax jurisdiction.

2.2.3 DUTY OF VIGILANCE

As a signatory of the United Nations Global Compact, Elior is committed to promoting and respecting, human rights principles and international labor and environmental standards along its entire value chain (see Section 2.1 above, "Corporate Social Responsibility: A Value Creation Driver"). It also ensures that it is not complicit in any breach of these principles or standards. All of these commitments are reiterated in the Elior Group Ethical Principles (see Section 2.2.1 above).

Over the years the Group has put in place procedures and systems that allow it to identify, assess and control its risks (see Chapter 3, Section 3.2. "Risk Management"). For example, since 2012 Elior France has had a Responsible Procurement Charter, which formally documents what the Group expects from its suppliers in several areas, such as quality, food safety, environmental protection, ethics and labor standards. This Charter - which all of our suppliers are asked to sign - was updated in 2017 to incorporate the Elior Group Ethical Principles and focus more strongly on the notion of vigilance in relation to the value chain. We also send a questionnaire to our main suppliers so we can assess their degree of corporate responsibility maturity, notably in terms of how they address their supply chain risks.

In order to reduce the environmental and social risks arising from our operations - particularly our supply chain - we have set ourselves the objective of gradually increasing the proportion of certified food and non-food items that we purchase (see Section 2.4 below, "Responsible Procurement"). Certifications act as a guarantee that international or local environmental and/or social standards have been respected. In 2020, 13% of the Group's purchases were certified products.

The procurement risk map

In 2017, a new Duty of Vigilance Act was introduced in France, which requires companies over a certain size to draw up a "Vigilance Plan" in order to identify and prevent social and environmental risks along their entire value chain (including for suppliers and sub-contractors). The companies concerned are also required to report on their implementation of the Vigilance Plan, notably in their annual management report.

In line with this new Act, in 2018 we set up a multi-

disciplinary steering committee (comprising representatives from the procurement, audit, CSR and quality departments etc.) to draw up the Group's first risk map for its main procurement categories (both food and non-food) in France.

The main risks related to Elior France's supply chain were identified and hierarchized following a four-step process, which involved:

  • Identifying risks by procurement category.
  • Identifying suppliers' home countries and country risks.
  • Conducting interviews (internally and with an external panel) and additional bibliographic research in order to hierarchize the identified risks.
  • Mapping the risks and putting in place an action plan.

Our 12 main procurement categories in France (seafood, fruit and vegetables, cleaning products, etc.) - representing over 30,000 food and non-food items - were analyzed and the following risk categories were identified:

  • Working conditions: pay, forced labor, child labor, etc.

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Corporate Social Responsibility 2

Conducting Business Responsibly

  • Health and safety of workers and consumers.
  • Communities and regional development: living and housing conditions, land and property rights and access to natural resources.
  • The environment: use of resources, biodiversity, pollution, waste and climate change.
  • Animal welfare: breeding and slaughter conditions.

Based on the results of this risk mapping process and the responses to the above-mentioned supplier questionnaires, in 2019 we began a process to map our main supplier risks at all levels in order to classify the risks in terms of the probability of their occurrence and their severity. This is a long and complex process in view of the number and diversity of our suppliers and subcontractors but it will enable the Group to achieve compliance with the first level of France's statutory requirements concerning the duty of vigilance. As a second stage we will extend the supplier mapping process to all of our subsidiaries based outside France as well as

to our clients and sub-contractors. Once all of the risk maps have been completed, in the following two fiscal years we will draw up precise and detailed action plans aimed at reducing the identified risks and will put in place the resources necessary for tracking those risks.

In addition to this risk-mapping, a process is currently under way to select a system that will allow the Group to analyze its supplier portfolio and rapidly detect those suppliers whose past behavior may pose a risk. This process - which was launched in 2018-2019 - has been significantly delayed by the Covid-19 pandemic.

The solution we opt for will need to be able to comprehensively manage the supplier assessment process (i.e. sending questionnaires, analyzing the responses and archiving and updating the related data). It may also be used in the future to analyze our B2B client portfolio in order to meet the requirements of the Sapin II Act.

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 65

  • Corporate Social Responsibility

Promoting a Tasty, Healthy and Sustainable Diet

2.3 PROMOTING A TASTY, HEALTHY AND

SUSTAINABLE DIET1

Elior feeds four million guests every day in the Business & Industry, Education, and Health & Welfare markets. Our mission is to offer great-tasting, healthy and sustainable food at all times and all stages of life, to improve people's health and well-being and minimize the environmental impact of our operations.

In order to develop a worldwide nutrition and health strategy to be applied in all our geographic regions, and propose the great-tasting, healthy and sustainable food that our clients and guests expect, in 2019 we decided to create the post of Chief Nutrition Officer.

Drawing on a network of local nutrition officers based in the Group's operating entities, the Chief Nutrition

Officer's work is focused on three main areas: selecting products, designing menus and raising guests' awareness about making the right nutritional choices.

By offering our guests healthy and sustainable choices, we are actively contributing to the UN's Sustainable Development Goal 32: "Good health and well-being".

In view of the worldwide Covid-19 pandemic, and the food inequalities that it has exposed and sometimes deepened, our responsibility as a community caterer is more than ever to guarantee a healthy, balanced diet for everyone. The current health crisis has clearly shown the major importance of this pillar in the Group's strategy and the responsibility that goes with it.

2.3.1 DESIGNING GREAT-TASTING, HEALTHY AND SUSTAINABLE OFFERINGS

In all of our host countries, we take care to devise great- tasting, balanced menus that are tailored to each client and guest profile. So as to provide affordable solutions that satisfy everyone's nutritional requirements, we draw on the nutrition recommendations issued by internationally-recognized bodies (such as the World Health Organization) as well as national standards specific to the countries where we operate (such as the PNNS, France's National Nutrition and Health Program).

Based on work carried out in prior years by the Nutrition Department, the Group has set itself the objective of gradually increasing, year after year, the proportion of whole-food and plant-based products in its purchases as well as the proportion of vegetarian menus.

Focusing on the taste and nutritional quality of ingredients

Elior strives to enhance the nutritional profile of its recipes while at the same time reducing the impact of its procurement process on the planet's ecosystems. We carefully select and put together the ingredients we use in our recipes and develop offerings that are suited to

guests' new expectations. In designing our offerings, we draw on the expertise of our 571 nutritionists.

The guidelines issued by leading nutrition organizations recommend increasing the proportions of plant-based produce in our diets, such as beans and pulses (chick peas, lentils, etc.), fruit and vegetables, seeds (sesame, chia, etc.) and nuts. We are therefore developing our use of those types of ingredients, both in terms of range and quantity. We want to diversify the sources of protein in our offerings by focusing on plant-based produce and we place particular importance on using seasonal fruit and vegetables (see the paragraph on seasonal produce in Section 2.4.1 below, "Prioritizing Products from Sustainable Agriculture").

In 2019-2020,whole-food and plant-based ingredients represented 17.0% of the Group's total food purchases. This was slightly less than the previous year, as there were fewer guests per restaurant which meant we had to close some stands - including some offering vegetarian menus

  • in order to adapt production volumes to the operating context.
  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2 SDG 3: "Good health and well-being": Ensure healthy lives and promote well-being for all at all ages.

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Promoting a Tasty, Healthy and Sustainable Diet

Since 2019 we have prioritized increasing the proportion of vegetarian recipes we offer in our menus. A recipe is considered to be vegetarian when it does not include any meat or fish. However, it does need to contain other sources of protein, which can be plant-based (beans, pulses, seeds, etc.), dairy (milk, cream, cheese) or egg- based. A plant-rich diet (including fruit, vegetables, beans and pulses, wholegrain cereals etc.) with less animal-based products is better not only for people's health but also for the environment.

Elior France's Business & Industry division therefore offers its guests at least one vegetarian option for every meal. And the Education division offers a full-course vegetarian option once a week.

As at September 30, 2020, the Group's operating entities had over 80,000 recipes, of which 19.3% were vegetarian - almost 4 percentage points more than the previous year.

Performance indicator

2019-2020

2018-2019

% vegetarian recipes

19.3%

15.5%

Nutritional offerings tailored to specific needs

To help improve the well-being of guests in health &

or multiple disabilities). We regularly forge partnerships

welfare establishments (hospitals, retirement homes, etc.),

with clients, nutritionists, doctors and chefs to develop

we offer innovative solutions specially adapted to the

service offerings tailored to the specific needs of those

pathologies that affect patients' or

residents' ability to

guests.

absorb nutrients (e.g., malnutrition,

age-related illnesses

Examples of offerings*

Country

Name of offering

Description

The BeWell offering encourages guests to make the best possible nutritional

choices. Adapted to all of Elior North America's market sectors and all of its

United States

BeWell

guests' age ranges, BeWell focuses on high-quality, nutritious foods in order

to provide guests with healthy choices and transparent nutritional

information.

France

Idequatio

An offering for seniors, tailored to each guest's degree of dependence so

they can continue to enjoy mealtimes.

An offering developed by Elior Entreprises to respond to consumer trends,

France

Les plaisirs sains

such as flexitarianism, and demand for natural and organic ingredients as

well as healthy food made from simple, quality ingredients.

An offering that meets the individual nutritional requirements of seniors,

NutriAge is structured around three separate but inter-related phases:

Italy

NutriAge

-

Nutriscreen: carrying out a personalized nutritional diagnosis for

the guest

-

Nutriplan: drawing up a nutritional program specific to each guest

-

Nutrifood: implementing the plan together with the guest.

People who have dysphagia (swallowing difficulties) and are therefore at risk

of choking need texture modified food. As part of Elior UK's Texture

Modified Food offering, a speech therapist assesses each guest's swallowing

problems and prescribes the appropriate type of texture modified food.

United Kingdom

Texture Modified

Elior has been recognized for its innovative approach to Texture Modified

Food

Food by the Alzheimer's Society in being shortlisted in the Trailblazer of the

Year category at the Dementia Friendly Awards. In addition, one of its chef mentors won the Best Care Home Chef Mentor Award for her passionate work in the care sector developing the standards and training around Texture Modified Foods.

* Non-exhaustive list.

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  • Corporate Social Responsibility

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2.3.2 PROMOTING GOOD EATING HABITS

Our overriding aim is to provide nutritious food and make mealtimes moments to enjoy. And this is underpinned by our driving force of offering every one of our four million guests not only great food but also food that meets the highest standards in terms of health and nutrition (see Section 2.3.1 above, "Designing Great-Tasting, Healthy and Sustainable Offerings").

Ensuring nutritional transparency

More and more of today's consumers want to see clear and straightforward information about what they're eating. We meet this demand by going above and beyond simply following local regulations.

Due to the diversity of our guests, clients and host regions, each of our entities designs their own communication campaigns and events to guide guests in their food choices. Awareness-raising events on good eating habits are also regularly organized in our restaurants. Led by the Group's in-house nutritionists or external nutrition specialists, these events are intended to help guests understand the importance of eating well, such as by choosing seasonal fruit and vegetables.

In 2019, we went even further by launching Nutri-Score in France. This traffic-lightcolor-coded labeling system, which is used on front-of-packs in supermarkets, allows guests to see nutritional information at a glance, therefore helping them make healthier food choices. Having piloted Nutri-Score at several sites and studied the findings in conjunction with the teams of Professor Hercberg - Nutri- Score's creator - the Group now plans to roll out this system to as many of its French school canteens and corporate restaurants as possible. Since September 2020, the Nutri-Score system has been tested in four high schools and we are planning to launch it for elementary and middle schools.

Ultimately, we would like to use Nutri-Score to rate and improve all of our recipes before proposing them to guests. In 2019-2020, 89.4% of the Group's revenue was generated by entities that are testing at least one nutritional information tool or system.

Developing specific tools for communicating with children

Many of our entities are school caterers and our teams devise menus specifically adapted to children's nutritional needs, as well as designing educational programs about healthy eating habits. We seek to improve children's knowledge about different foods and their properties, as well as about the food chain and sourcing, to help them make responsible food choices and compile their own menus.

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Corporate Social Responsibility 2

Promoting a Tasty, Healthy and Sustainable Diet

Examples of concepts*

Country

Concept

Description

Weeky Daily is a new offering designed by Elior France's Education

division for the students and teachers of high schools, colleges and

universities. It is an app that guests can use to pre-order menus

France

Weeky Daily

comprising a main course (sandwich, salad or a hot dish), a seasonal

fruit and a dessert (a home-made pastry or fromage blanc), and

therefore responds to young people's new eating trends while

respecting Covid-19 social distancing rules.

Elior Italy's Mangiare al ritmo della natura program is intended to

Italy

Mangiare al ritmo della

encourage children to adopt healthy eating habits and learn the

natura1

importance of eating seasonal produce, all through fun activities and

events.

The Nutrifriends program was devised by Serunion to help school

Spain

Nutrifriends

children make healthy food choices on a daily basis. Developed in

partnership with a master chef, it encourages good eating habits and

a healthy lifestyle.

Elior North America has started to introduce its BeWell offering into

the schools it caters for to encourage children to eat more fresh,

seasonal fruit and vegetables (Fresh Picks) and discover new

United States

BeWell

ingredients (Food for Thought). BeWell for school children includes a

monthly nutrition newsletter (Nutrition News) as well as nutrition

programs taught in classes and communication campaigns in school canteens.

* Non-exhaustive list.

Attuned to guests' needs

(India) and Joyfood (Italy) - all designed to ensure we are

always attuned to guests' needs and give them the

At Elior, we place great importance on understanding and

information they want.

anticipating the changing needs and habits of our guests

so we can adapt our food offerings and the environments

In 2019-2020, some 4,000 Group sites carried out at least

of our restaurants and points of sale accordingly. We use

one guest satisfaction survey. This figure is lower than in

numerous different tools for this purpose (satisfaction

2018-2019 due to the Covid-19 crisis and lockdowns,

surveys, mystery guests, etc.) as well as digital solutions -

which meant that some of our restaurants could not

notably dedicated apps such as TimeChef (France), El Chef

conduct satisfaction surveys.

2.3.3 GUARANTEEING THE HIGHEST FOOD QUALITY AND SAFETY LEVELS

The health, safety and well-being of our four million daily guests are a key priority for us. Aware that zero risk does not exist, we apply the highest recognized standards and have put in place safety and security systems along our entire production chain.

Controls adapted to the Covid-19 crisis

Our number one priority response to the crisis was ensuring the health and safety of our employees, clients and guests. For all of the Group's entities this entailed creating additional controls. Elior Italy, for example, asked the independent firm that carries out its hygiene audits and micro-biological tests to add specific Covid-19 analyses to its list of controls.

  • Eating at nature's pace.

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 69

  • Corporate Social Responsibility

Promoting a Tasty, Healthy and Sustainable Diet

And in France, Elior Services Santé created over 40 protocols to be used by its healthcare hospitality services during the Covid-19 pandemic. These protocols were sent out to 500 health and welfare establishments to help control public health risks and avoid the risk of the virus spreading at any of Elior Services' sites.

Strict organizational procedures and regular controls

It is the responsibility of each operating entity's CEO to ensure that the ingredients and products they use fully comply with the laws, regulations and industry standards in force in their particular country as well as with the Group's own food safety rules.

To guarantee that the highest safety levels for clients and guests are met on a daily basis, we have deployed rigorous organizational procedures that enable us to strictly control food safety. In particular, we use the HACCP (Hazard Analysis Critical Control Point) method, which allows us to identify, assess and control significant food safety hazards. Dedicated training sessions are given to employees to ensure compliance with HACCP principles and best hygiene practices.

Over 17,000 employees in Elior subsidiaries in Italy, Spain, Portugal, the UK and India received hygiene training in 2019-2020.

In addition, hygiene audits and product analyses are regularly conducted by either internal or external auditors to check that the products used in the meals we prepare are fully compliant and that we meet the relevant food safety and hygiene standards. These audits and analyses are also a way for us to check other factors such as the cleanliness of premises and equipment, operating agents' practices, and compliance with cold chain standards.

In 2019-2020, Elior carried out over 9,700 hygiene audits worldwide and more than 52,800 product analyses. Both of these figures were lower than in the previous year, for two main reasons. First, the Covid-19 lockdowns led to the closure of some of our restaurants which meant that no audits could be carried out. And second, many of the sites where our restaurants are located implemented strict rules about third parties coming onto their premises so in some cases the auditors were not authorized to enter the restaurants.

Certification of procedures and policies

Some Group entities have voluntarily had their sites audited by independent certification bodies in order to demonstrate their high levels of quality and food safety. At September 30, 2020, Elior France, Elior Italy, Elior India and Serunion Spain had 42 sites with ISO 22000 certification - the benchmark international standard on food safety management.

In France, Elior Services created a specific certification program in 2019-2020 called Label Mesures sanitaires

COVID-19. Designed in conjunction with Afnor Certification - France's leading certification body - the program comprises an independent audit guaranteeing that the Covid-19 measures deployed at client sites meet the required health and safety standards and that Elior Services can therefore continue to operate at those sites. Once certification has been obtained for a particular client site the official certificate can then be displayed.

Anticipating risks and identifying emerging issues

The quality and food safety teams at all of the Group's entities have an ongoing oversight procedure in place (scientific, technological and regulatory) so they can adapt their control policies and processes where necessary. These teams are responsible for determining food safety standards and methods.

To help anticipate risks and regulatory developments relating to food safety, for many years now, the Group has had a Scientific Committee in France, comprising independent specialists (including nutritionists, pediatricians, toxicologists and microbiologists) as well as members of the Group's teams (food quality, safety,

procurement etc.). This committee issues recommendations about nutrition, health and product traceability. However, due to the Covid-19 restrictions imposed in the first half of 2020, it could only meet once during 2019-2020.

Rigorously selected suppliers and products

At Elior we work closely with all of our value-chain participants, especially suppliers, in order to offer our guests healthy, safe and high-quality products (see Section

2.4 below, "Responsible Procurement"). We ensure strict traceability of the ingredients included in our menus and carry out audits to verify the quality of our supplies.

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Corporate Social Responsibility 2

Promoting a Tasty, Healthy and Sustainable Diet

Suppliers are audited using specific scoring charts that vary depending on the type of product and supplier concerned. These charts focus on the key food safety issues affecting each particular profession (e.g., distributor, manufacturer, artisan, abattoir, milk producer, importer) and the audits are performed based on a full traceability test, starting from when the raw materials are received through to the Group's distribution of the end product. In France, recommended areas of improvement and the supplier's corresponding undertakings are set out in a written post-audit report, and in its following audit, the Group checks that its recommendations have been implemented.

Tests are also regularly carried out to ensure the quality of the ingredients delivered to the Group's restaurants by its suppliers.

In the same vein, as part of its Impacts+ CSR strategy, Elior Services prioritizes the use of eco-certified and concentrated products through its "100% Responsible" range. All of its client sites are supplied with detergents that do not contain any products classified as CMR (carcinogenic, mutagenic or toxic for reproduction) or endocrine disruptors, and which are plant-based (made from sugar beet, corn, bran, wheat, etc.) and 100% bio- degradable. It also offers VOC-free products, which are odorless and do not pose any health risk for employees, patients or clients.

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  • Corporate Social Responsibility

Responsible Procurement

2.4 RESPONSIBLE PROCUREMENT1

As a caterer, Elior firmly believes it has a key role to play in promoting and developing sustainable agriculture which forms the basis for healthy, balanced eating.

Because our environmental impact is primarily related to the raw materials directly or indirectly used in our meals (see Section 2.5 below, "A Circular Model"), we have decided to focus our efforts on building a sustainable supply chain. In this way, we are actively contributing to the UN's Sustainable Development Goal 22: "Zero hunger". In order to develop our procurement in line with our nutritional policy (see Section 2.3 above, "Promoting a Tasty, Healthy and Sustainable Diet") and minimize our impact on ecosystems and the climate, we have set ourselves two major objectives:

  • Increase the proportion of our responsible supplies by prioritizing local, seasonal and certified produce.
  • Increase the proportion of responsible packaging and consumables (knives and forks, glasses, food containers, etc.).

In addition to these two major objectives, we are actively working on the issues of responsible fishing and animal welfare, as well as the impact that certain product categories can have on biodiversity and forests (palm oil and soy).

We are especially attentive to the relations we have with our suppliers in order to ensure that they deliver us high- quality products and that they apply best social and environmental practices. The Group regularly carries out supplier audits to control the quality of their operations and the quality and traceability of their products. A total 282 supplier audits were performed in 2019-2020. This figure was lower than in 2018-2019 because of the lockdowns imposed in the countries where the Group operates. Also, the Covid-19 safety measures introduced by suppliers meant that in some cases external parties were not able to come onto their sites.

The Covid-19 crisis has highlighted the Group's increased dependence on international supply chains and revealed a crucial need for us to rethink our procurement processes in order to create a supply chain from producer to consumer that is centered on safety and value rather than just on price. Not only will this benefit our guests, but it also represents a strategic necessity for the Group's business. At Elior, creating value for our ecosystem covers a wide range of issues including product diversity, unfaltering food safety, preservation of land and resources, fair and equal treatment of farmers, and great tasting food. The combination of these factors is moving our Group towards even more local and seasonal supplies.

2.4.1 PRIORITIZING PRODUCTS FROM SUSTAINABLE AGRICULTURE

One of the objectives we have set ourselves is to increase the proportion of seasonal, certified, local and/or organic produce within our overall purchases. The underlying aim of this approach is not only to prioritize products grown using eco-friendly farming practices but also to make a sustainable contribution to the economic development of the regions in which we operate.

During 2019-2020, our proportion of local food purchases was lower than the previous year. This was because Covid- 19 forced us to temporarily adapt our food offerings in all of our markets and segments. We therefore had to use sourcing solutions that are more suited to public health crises and which minimize waste, such as ready-made, dry and/or frozen products. The resulting changes in the procurement mix had a negative effect on the proportion of local purchases, as these mostly comprise fresh and ultra-fresh produce.

Some Group entities have gone a step further in their drive to support sustainable agriculture and applied for certification for some of their sites. Since 2016, two of Serunion's central kitchens (in Malaga and Almeria) have been certified as 100% organic meal production centers by the CAAE, Spain's leading organic food certification body. Serunion was also the first contract caterer in Spain to receive, for two of its restaurants, the "sustainable restaurant" certification from AENOR (the Spanish Association for Standardization and Certification). This certification covers a number of different areas including nutrition, responsible procurement, waste management and raising guests' awareness about sustainable development.

In France, Elior has teamed up with organizations such as the Vergers écoresponsables ("responsible orchards") program, which was initially just for apples but now covers peaches, nectarines, apricots and pears.

  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2 SDG 2: "Zero hunger". End hunger, achieve food security and improved nutrition and promote sustainable agriculture.

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Corporate Social Responsibility 2

Responsible Procurement

By partnering this program, we are helping to protect bees and other pollinators and bio-diversity in general, as well as supporting the fruit-growing industry's ecological transition. Lastly, we are in the process of transforming our ingredient supplies and are sourcing a good

proportion of our products from suppliers that are certified for their quality and/or sustainability, such as RUP bananas, HVE carrots in France, Vergers écoresponsables apples and pears, and GlobalG.A.P melons and oranges.

Performance indicators

2019-2020

% purchases of certified food produce(1)(2)

13.7%

% purchases of local food produce(1)

12.7%

% purchases of organic food produce(1)

3.2%(3)

  1. In value terms (2) Excluding Elior North America (3) Excluding Elior India (see Section 2.7.1 below, "Non-Financial Reporting Process")

Animal welfare

In 2017 Elior published a position statement on animal welfare, based on the five freedoms for farm animals issued by the UK Farm Animal Welfare Council:

  • Freedom from hunger or thirst by ready access to fresh water and a diet to maintain full health and vigour.
  • Freedom from discomfort by providing an appropriate environment including shelter and a comfortable resting area.
  • Freedom from pain, injury or disease by prevention or rapid diagnosis and treatment.
  • Freedom to express (most) normal behaviour by providing sufficient space, proper facilities and company of the animal's own kind.
  • Freedom from fear and distress by ensuring conditions and treatment which avoid mental suffering.

Available in French, English, Spanish and Italian, this position statement - which was sent to all of the Group's entities - is the benchmark for all of its countries and markets. It sets out the priority animal welfare action areas identified by Elior: traceability, reasonable use of antibiotics, welfare during transport, etc.

We are, however, keenly aware that we cannot improve animal welfare along the entire supply chain by acting alone, which is why in 2018 the Group became one of the founding members of the Global Coalition for Animal Welfare (GCAW). GCAW is a global platform bringing together major food companies and animal welfare experts with the aim of improving animal welfare standards. GCAW's members have identified five priority work streams: cage-free policies, improved broiler chicken welfare, farmed fish welfare, antimicrobial resistance, and global standards for transportation and slaughter.

The Group's overall animal welfare commitments are rounded out by local undertakings given by its entities on an individual basis. For instance, Elior UK has issued its own animal welfare policy and supports the UK

government's Live Transport Welfare initiative, which works towards improving animal transport conditions. In addition, all of its UK-based meat and dairy suppliers have to carry the Red Tractor label, certifying that their practices meet high health and environmental standards.

In France, Elior joined forces with Compassion in World Farming (CIWF) in 2017 in order to formally document its animal welfare requirements vis à vis its suppliers and create systems and processes that can be adapted to the needs of each business (such as audit checklists and specific policies). An animal welfare section has therefore been added to the supplier audit checklist and the Group clearly informs its suppliers about its animal welfare policy.

In 2020, Elior maintained its score of 3 (out of 6) in the Business Benchmark on Farm Animal Welfare (BBFAW) published by the CIWF. An internationally recognized standard, the BBFAW is a global measure of company performance on farm animal welfare covering the world's 150 largest food companies.

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  • Corporate Social Responsibility

Responsible Procurement

Cage-free eggs

As part of our commitment to animal welfare, we have undertaken to increase the proportion of egg purchases (whole/shell and liquid eggs) and egg-based products (powder, omelets, egg whites, etc.) from hens bred in cage- free conditions (i.e. barn-laid,free-range or organic eggs).

In 2019-2020, 9.2%1 of the eggs purchased by the Group came from cage-free sources.

Certain Group entities particularly stand out in this area, such as Elior UK and Elior Italy, whose cage-free eggs accounted for 40.5% and 28.7% of their total egg purchases respectively in 2019-2020.

Responsibly sourced seafood

For over ten years now, we have deployed a responsible procurement policy designed to protect marine biodiversity. And going forward we want to further increase our purchases of seafood products that carry labels given by organizations such as the Marine Stewardship Council (MSC). These labels guarantee that the seafood has been fished sustainably, leaving enough fish in the oceans and respecting marine habitats. In 2019- 2020, 35.7% of the seafood purchased by the Group (in volume terms) was responsibly sourced. This percentage figure is more than five points higher than in 2018-2019, clearly demonstrating the Group's overall commitment and the individual actions undertaken by its entities to offer a higher proportion of responsible seafood.

Performance indicator

2019-2020

2018-2019

% responsibly sourced seafood(1)

35.7%(2)

29.4%

  1. In volume terms (2) Excluding Elior India (see Section 2.7.1 below, "Non-Financial Reporting Process").

At the same time, several Group entities have teamed up with national and/or international specialists to improve their seafood sourcing practices.

Elior UK follows the Marine Conservation Society's Good Fish Guide, which ensures that 'At Risk' and 'Endangered' species never appear on its menus. This means that the fish it uses always comes from sustainable stocks, playing a key role in guaranteeing the future of marine wildlife.

Seasonal produce

Today's consumers are increasingly attentive to whether the fruit and vegetables they eat are in season. Our

procurement team has therefore developed a tool that tracks the Group's purchases of seasonal fruit and vegetables. This tool is currently being used at Elior France, Elior Italy and Serunion (in both Spain and Portugal) and our aim is to roll it out to the Group's other subsidiaries.

Elior's teams can use the tool to obtain data and ultimately change their procurement behavior by making more information-driven choices. In 2019-2020, 88% of the fruit and vegetables used by Elior Italy were seasonal. In France the high season for cherries is in June - over 99% of the cherries used by Elior France are consumed in June and the rest in July.

2.4.2 ELIMINATING PRODUCTS FROM THE SUPPLY CHAIN THAT

CONTRIBUTE TO DEFORESTATION

Safeguarding the world's forests is something we take very seriously, which is why we seek to eliminate from our supply chain any products that directly or indirectly contribute to deforestation, particularly palm oil and soy.

Palm oil

We endeavor to minimize our use of non-sustainable palm oil. However, in their meal preparation process some of our entities do sometimes use food oils that contain palm oil. The Group therefore ensures that the palm oil it uses directly is certified as sustainable. These certifications

from organizations such as the RSPO (Roundtable on Sustainable Palm Oil) guarantee (i) traceability of the palm oil, (ii) that no new primary forest or any other area of high conservation value is cleared for new plantations and that the living conditions of workers, smallholders and local populations are respected.

In 2019-2020, 100% of the palm oil purchased by Elior UK was certified as sustainable (by the RSPO, GreenPalm or another recognized certification body).

  • Excluding Elior India (see Section 2.7.1 below, "Non-Financial Reporting Process").

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Responsible Procurement

Soy

We are also particularly vigilant about the environmental impact of soybean production and have clearly identified the risks of deforestation related to the feed given to animals whose meat is sourced for use in our restaurants.

Soy is the leading cause of forest conversion and deforestation imported into France and Europe in general. In the space of just a few years, this raw material has become one of the world's largest crops by cultivated area (123 million hectares worldwide1), resulting in the devastating effects of forests and savannas being converted into agricultural land and depleting natural ecosystems, particularly in South America and the United States which account for over 66% of the world's soy production.

Elior France calculated that for fiscal 2019-2020 its indirect soy footprint - i.e. the consumption of soy deriving from animal-based products (meat, eggs and dairy) that the entity purchases - amounted to 10,930 tonnes.

In 2018, Elior Group in France joined an initiative launched by the World Wildlife Fund (WWF) to create a working group made up of representatives from several major players in the retail, food and contract catering

sectors. Supported by the Alliance for the Preservation of Forests, the Duralim platform for sustainable animal feed and the EarthWorm Foundation, this working group defined their shared vision of responsible soy production and drew up a joint action plan aimed at creating soy supply chains that avoid the conversion of natural ecosystems.

In 2020, Elior France joined the Duralim association in order to participate in the joint preparation of specifications and traceability methods in the animal feed sector as well as measures the sector can take with respect to intermediaries. In this way, Elior is also raising awareness within its sphere of influence and among its stakeholders about the consequences of imported deforestation which concerns, particularly in the value chain, soy used for animal feed in France.

Furthermore, in order to meet its clients' specifications, Elior France purchases meat bearing a wide range of labels attesting to the quality of the animal feed used (organic, Label Rouge, etc.). And since 2005, Elior France's approved product list has included produce certified by the Bleu- Blanc-Coeur association, which encourages the use of plants that are natural sources of Omega 3 in animal feed (such as linen), which reduce the proportion of soy.

2.4.3 PROMOTING THE USE OF RESPONSIBLE PACKAGING AND

CONSUMABLES

Developing a circular model means changing our guests' consumption habits so as to minimize waste, particularly plastics.

To reduce the need for fossil fuels and minimize the amount of waste generated by our business, we have set ourselves the objective of increasing our proportion of reusable and/or recyclable packaging and consumables (knives and forks, glasses, food containers, straws, etc.) that are reusable and/or recyclable. The plastic

equivalents used can be bio-based (made from polylactic acid, corn, sugarcane, bamboo pulp, etc.), compostable or biodegradable.

In 2019-2020, 17.3% of the packaging and consumables used by the Group were classified as responsible. This represents nearly a three percentage-point rise compared with 2018-2019, clearly illustrating how we are working towards our goal of increasing the proportion of responsible packaging and consumables we use.

Performance indicator

2019-2020

2018-2019

% responsible packaging and consumables used(1)

17.3%

14.4%

(1) In value terms

When the use of plastic is unavoidable for technical reasons (such as plastic straws required for therapeutic purposes), we strive to maintain our circular model by optimizing the materials used and prioritizing reusable and/or recyclable products. For further details about our approach to developing a circular model, see Section 2.5 below, "A Circular Model".

  • http://www.fao.org/faostat/en/#home

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 75

  • Corporate Social Responsibility

A Circular Model

2.5 A CIRCULAR MODEL1

The Group is actively helping to develop a circular economy and is committed to fighting all forms of waste

  • notably food waste - as well as to reusing waste in order to convert it into resources and give it a second life.

All of our actions in this area contribute to achieving the UN's Sustainable Development Goal 122: Ensure sustainable consumption and production patterns.

2.5.1 REDUCING FOOD WASTE

As a caterer, fighting food waste is a key priority for Elior and we are trying to reduce it across the value chain, from the supply chain through to kitchens and restaurants. We are also working at the end of the value chain to redistribute unsold meals and reuse food waste.

An in-house workshop on finding practical and operational solutions for reducing waste was organized in October 2019, attended by representatives from many of the Group's professions, functions and countries. This anti-waste CSR round-table was also an opportunity to raise awareness among all of our stakeholders about how to reduce food waste.

High-quality supplies and menus

To minimize our environmental impact and at the same time offer guests healthy, balanced menus, we have undertaken to prioritize purchases of products from sustainable agriculture (see Section 2.4, "Responsible Procurement") and to increase the proportion of our vegetarian offerings (see Section 2.3.1, "Designing Great- Tasting, Healthy and Sustainable Offerings").

The way we design our menus is one of our best arms in the fight against food waste. To make sure guests are offered the food they want and therefore help prevent waste, we remain closely attuned to their needs, regularly conducting satisfaction surveys (see Section 2.3.2, "Promoting Good Eating Habits"). The tests we carry out to ensure the quality of our menus likewise help to minimize waste.

In order to identify which recipes guests prefer, Elior France's Education division has set up a Taste Observatory whose teams carry out assessments every day at selected sites to identify which food items tend to be left on the plate and which recipes are the most and least popular.

Waste-reduction solutions

An essential aspect of our efforts to reduce waste in our kitchens is training employees in effectively managing raw materials inventories and producing just the right quantities so as to avoid perished, surplus or unsold products. In 2019-2020, 85% of the Group's revenue was generated by entities that are testing at least one waste- reduction solution.

Another key element in fighting waste is the emergence of specialized digital systems, such as diagnostic tools for measuring and analyzing different sources of waste. Several Group entities have entered into partnerships in this domain. For example, Elior UK has put in place a program called OLIO Food Waste Heroes, through which surplus food can be donated and safely redistributed. OLIO organizes the collection and distribution of the donated food among local communities. To date, Elior UK and its subsidiaries have donated over 8,000 kg of food under this program, representing the equivalent of more than 19,000 meals. Another of Elior UK's initiatives - launched through its Lexington brand - is Trashed, which entails the creation of recipes using leftovers. This concept was a finalist in the Footprint Awards in November 2019.

Since February 2019, Elior has joined forces with Too Good To Go, so as to reduce food wastage in its corporate restaurants. Through this program, Business & Industry guests can buy a "surprise food basket" made up of the leftovers from that day. They can order their basket at a cut price on the free Too Good To Go app and then pick it up after lunch or at the end of the day. This concept means that neither the work of our teams nor any food that is still edible goes to waste. It has been rolled out in France and Spain at several pilot sites, and is already saving hundreds of meals a month from being thrown away.

  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2 SDG 12: "Ensure sustainable consumption and production patterns".

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Corporate Social Responsibility 2

A Circular Model

Teaching guests to be eco-friendly

Part of food waste is what's left on people's plates when they have finished eating. That is why we organize events and campaigns to encourage our guests to waste less food. And we are also changing the way we distribute and serve food. In our self-service restaurants, for example, we might put the bread basket at the end of the serving line rather than at the start, or offer choices between small or larger-sized dishes. We believe we have a responsibility to raise our guests' awareness about what food waste entails so they too can help drive the change we are trying to achieve.With this in mind, the Group's various entities regularly organize events in their restaurants as well as communication campaigns adapted to the specific characteristics of their markets, so that both adults and children can actively take part in the fight against food waste, whether in a school canteen, corporate restaurant or at home.

Another example of our efforts in this area is the more than 30 anti-waste workshops we held in 2019-2020 in association with Expliceat, a firm specialized in combating food waste. Unfortunately, the momentum of this program was halted when schools had to close due to France's national lockdown. The Group is currently looking into other ways of continuing this educational approach with young people.

Redistributing unsold meals

Highly aware of society's inequalities when it comes to access to food, we help fight against food insecurity by redistributing unsold meals through non-profit organizations or specialist companies, whenever permitted under local legislation.

We have been a partner of the French Food Bank Federation (FFBA) since 2004, donating surplus food from our central kitchens. In 2019-2020, our central kitchens in France donated over 16 tonnes of food to our partner nonprofit organizations.

2.5.2 MINIMIZING THE GROUP'S ENVIRONMENTAL FOOTPRINT

Aware of the environmental impact of our business, we seek to reduce our footprint at every stage of our value chain. Although most of our business is carried out at client sites, which we do not own, each of our entities implements measures adapted to their own specific characteristics aimed at reusing more waste, reducing their use of energy and water and narrowing their carbon footprint.

Raising guests' awareness about the importance of sorting waste

Reducing waste and increasing the practices of reusing and recycling largely depends on how effectively guests sort their waste at the end of their meals. Whenever possible the Group puts in place waste-management facilities to make it easier for guests to sort and recycle.

Helping clients and guests to be more eco-friendly is a key priority for our entities, which for the past several years have implemented measures to help them reduce food waste (see "Teaching guests to be eco-friendly" in Section 2.5.1 above) and manage waste in general.

Reusing and recycling organic waste

We have set ourselves the target of collecting organic waste for reuse/recycling at all of the sites where we are contractually responsible for waste management.

At September 30, 2020, 89.0% of our sites1 collected their organic waste for reuse or recycling.

Waste collection and recycling is organized at site level and differs depending on the type of waste concerned. Pick-up and processing are always outsourced to specialist service providers.

We have established partnerships with recycling professionals to provide our clients with the best solutions. In France for example, Elior has teamed up with Moulinot, which specializes in recycling food waste into biogas or compost. A total 630 tonnes of organic waste has been collected from 89 sites since January 1, 2019 thanks to this partnership.

  • Sites at which the Group is contractually responsible for waste management.

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Performance indicators

2019-2020

2018-2019

% sites collecting organic waste for reuse/recycling(1)

89.0%

83.2%

% used cooking oils reused/recycled(2)

81.0%

84.0%

  1. Sites for which the Group is contractually responsible for waste management. Excluding Elior Italy.
  2. Notably in the form of bio-fuel.

Reducing single-use packaging and products

As the best type of waste is waste that never existed in the first place, we want to reduce, or in some cases totally eliminate, single-use plastic packaging and products. However, as the safety and well-being of our guests are our number one priority, the Covid-19 pandemic in 2019- 2020 meant that we had to temporarily adjust some of our offerings, and in some cases this involved incorporating single-use packaging. The reasons for this were:

  • To limit contact between our employees and guests.
  • To limit footfall in restaurants by proposing take-away solutions.

Otherwise, our underlying aim of reducing single-use packaging and products is the same as before. A prime example is Elior UK's restaurants, which eliminated plastic straws and stirrers back in 2018.

In France, Elior Entreprises now offers its Business & Industry clients a range of sustainable products made from organically sourced and bio-degradable materials such as wood, cardboard, bagasse (sugarcane pulp), PLA (a plant-based plastic substitute) and rPET (recycled polyethylene terephthalate).

In connection with our commitment to increase the proportion of responsible packaging and consumables we buy (see Section 2.4.3, "Promoting the Use of Responsible Packaging and Consumables"), our entities enter into partnerships with specialist firms. For example, Elior North America and Elior UK have teamed up with Vegware, a company that makes single-use packaging out of recycled and renewable materials that have a lower carbon footprint than plastics. When the Covid-19 pandemic broke out, Elior UK quickly created a new takeaway offer called Good to go, and chose Vegware for the packaging solution.

When it is difficult to avoid a particular type of waste, the best solution is to recycle it. For instance, Arpège - an Elior France subsidiary - is currently working with other food industry players to develop a large-scale system for recycling PLA plastic yogurt pots in France.

Energy saving measures

At Elior, we are committed to reducing our energy consumption. Although most of our business is carried out at our clients' premises, we take action to improve on- site energy efficiency, such as by installing eco-efficient equipment and developing the production of renewable energy from organic waste.

Several Group entities have been awarded certifications attesting to the quality of the energy management and/or energy efficiency at their sites.

We also train our teams about adopting environmentally- friendly practices to cut down on energy use at our sites (systematically closing cold-storage room doors, switching off unused equipment, etc.) through awareness- raising campaigns.

In order to identify the main sources of energy use, and in accordance with the applicable regulations, the Group carried out energy audits (electricity, gas, heating oil, and fuel for company vehicles) within all of its French entities in 2019-2020. Thanks to these audits, action plans have been drawn up to reduce energy use in our school canteens in France.

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Corporate Social Responsibility 2

A Circular Model

Measuring greenhouse gas emissions

In 2019, the Group performed its first carbon footprint assessment1 covering its full scope of responsibility, based on the three categories of emissions (Scopes 1, 2 and 3) defined in the World Resources Institute's GHG Protocol:

  • Scope 1: direct emissions related to the combustion of fossil fuels (oil, gas etc.) used by the sites for which the Group holds the energy contract as well as those generated by leaks of refrigerants from owned or controlled equipment. This scope also includes emissions from the Group's vehicle fleet.
  • Scope 2: indirect emissions related to purchased or acquired electricity, heat and cooling.
  • Scope 3: other indirect emissions (notably from purchases of raw materials, energy-related emissions from sites for which the Group does not hold the energy contract, upstream logistics, downstream distribution and employee commuting).

For 2019-2020, the calculation of the Group's carbon footprint was fine-tuned in relation to Scope 3,

particularly for purchases of food raw materials. This allowed us to identify the categories of ingredients that cause the highest level of emissions, which meant we were able to pinpoint action areas for improvement for 46% of our emissions. During the year we also able to fine-tune our methodology for calculating energy-related emissions thanks to the wider coverage of reporting on energy used at each Elior site. We therefore now have a robust methodology underpinning our work on continuing to reduce the Group's greenhouse gas emissions.

In 2019-2020, Elior's total emissions for its scope of responsibility - covering Scopes 1, 2 and 3 - amounted to

3.2 million tonnes of CO2 equivalent (TeqCO2). Scope 3 accounted for the largest amount of this (97%) followed by Scope 1 (2.2%) and then Scope 2 (less than 1%).

In view of the above methodology changes and the slowdown in business caused by Covid-19,year-on-year comparisons of Elior's total emissions are not meaningful. However, thanks to our improved calculation methods, we can now track average greenhouse gas emissions by meal. In 2019-2020, an average of 3.9 kg of CO2 equivalent was emitted per meal2.

* Sites for which Elior Group is not contractually responsible for energy supply

Energy-related emissions from sites where Elior is not contractually responsible for energy supply (gas and electricity) represent the Group's largest source of emissions (47% of total emissions), followed by emissions related to purchases of goods and services (46%). The

other significant sources for the Group (>7%) are the use of energy at sites where Elior holds the energy contract and the use of refrigerants at sites (managed and not managed by Elior), freight (upstream and downstream) and business travel and employee commuting.

  • The emissions calculated for performing the Group's bilan carbone carbon footprint assessment for its extended scope of responsibility (Scopes 1, 2 and 3) are based on data relating to its business activities and emissions factors. Extrapolations were performed when data was not available for certain geographic regions.
    2 Elior Services was not included in this calculation as it does not produce meals.

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 79

  • Corporate Social Responsibility

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2019-2020

Scope 1 - Direct emissions

2.2%

o/w refrigerants

48.2%

o/w energy for vehicles

21.0%

o/w on-site fuel combustion

30.8%

Scope 2 - Indirect emissions

0.6%

o/w electricity

100.0%

Scope 3 - Other indirect emissions

97.2%

o/w purchases of goods and services

47.8%

o/w other energy-related emissions

48.1%

o/w upstream transport and distribution

2.1%

o/w employee commuting

1.5%

o/w fixed assets

0.3%

o/w waste

0.2%

o/w business travel

0.1%

o/w sold products' end-of-life

0.1%

Since 2012, we have measured the greenhouse gas (GHG) emissions of our restaurants in France using a GHG measurement system based on the Bilan Carbone® method created by the French National Agency for the Environment and Energy Management (ADEME). This system has been specifically adapted to our contract catering business and it can be used by each individual restaurant to measure its own GHG emissions.

Elior Services also has a version of the system, tailored to its activities.

We can now also track GHG emissions per meal. In September 2020, Ansamble - an Elior France subsidiary - launched a carbon rating project at several sites, based on a methodology proposed by external consultants. Each meal is given a carbon performance rating from A to E, making guests visually aware of the carbon footprint of the meal they choose.

Further demonstrating our commitment to fighting climate change, and in tune with our stakeholders' expectations, in 2019-2020 we enhanced our environmental disclosures by taking part in the CDP climate change assessment. The CDP (formerly the Carbon Disclosure Project) scores companies based on their climate policies. This assessment will enable us to more effectively structure our approach to reducing GHG emissions, managing climate risks and adapting to climate change.

Water saving measures

Using water sustainably is a major objective for the Group as we consume large amounts of this resource either directly (at our sites) or indirectly (through our supply chain). To help meet this objective, we put in place innovative solutions across our sites to reduce their use of water and control the quality of the waste water they produce.

The measures we have undertaken include installing water-saving equipment, raising awareness among employees and clients about eco-friendly practices, and processing waste water to ensure its quality and reduce its impact on the environment.

80 . ELIOR GROUP. UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Ensuring Employees' Health, Safety and Development

2.6 ENSURING EMPLOYEES' HEALTH, SAFETY AND

DEVELOPMENT1

Because we believe that happy employees make happy guests, we want all of our 105,000 people to fulfill their potential. With this in mind we offer an attractive business model and take care to properly reward employees' work and engagement.

Placing HR at the very heart of our business, we apply a subsidiarity principle for many HR aspects of our organization. For example, a number of wide-ranging decisions and initiatives are taken directly in the Group's host countries (while remaining in line with its corporate strategy) so that they can match the local needs and expectations of its activities and employees. As part of this overarching policy, and with a view to implementing Group-wide measures that will drive the execution of its overall strategic plan, the Group Human Resources Department has set the following priority action areas:

  • Protecting employees' health, safety and well-being.
  • Building employee skillsets.
  • Encouraging promotions, mobility and internal career development.
  • Promoting diversity and inclusion.

By acting as a responsible employer, the Group is contributing to the UN's Sustainable Development Goal 82: "Decent work and economic growth".

The Covid-19 crisis has had a major impact on Elior, as national lockdowns and new health restrictions resulted in many of our sites having to close and reduced activity for those that did stay open. The Group therefore used short-time working and furlough schemes for much of its workforce and also had to lay off staff. Wherever possible, employees were asked to work from home. And when the rules allowed people to come back to work, strict health and safety measures were put in place to protect both our employees and our guests.

2.6.1 EMPLOYEE DATA

At September 30, 2020, the Group had over 105,000

We are committed to improving our employees' quality of

employees based in six main countries: France, India, Italy,

life and offering them career development opportunities

Spain, the United Kingdom and the United States.

as we believe that these two factors are essential for

motivating and retaining our people. At September 30,

2020, the average seniority of Group employees on a

permanent contract was seven years.

Employees by country(a)

Number

%

France

43,781

41.6%

Spain

19,625

18.6%

United States

15,597

14.8%

United Kingdom

11,086

10.5%

Italy

10,345

9.8%

India

4,434

4.2%

Portugal

301

0.3%

Société Monégasque de Restauration(b)

50

>0.1%

Group total(c)

105,219

100.0%

Total workforce (permanent and non-permanent employees) on the payroll at September 30, 2020 (b) SMR was included in Elior France in 2018-2019(c) Excluding Elior Luxembourg

Hires and departures

2019-2020

Total new hires*

Number

92,453

Breakdown by type of contract: permanent/non-permanent

%

21.6%/78.4%

Total departures*

Number

95,422

Breakdown by type of contract: permanent/non-permanent

%

25.5%/74.5%

*Excluding transfers and changes of operator

  • Tables summarizing the Group's non-financial indicators are appended to this Chapter (see Section 2.7, "Methodological Note") including year-on-year changes (where available).
    2Promote sustained, inclusive and sustainable economic growth, full and productive employment and decent work for all.

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2.6.2 GUARANTEEING EMPLOYEE HEALTH AND SAFETY

At Elior we are committed to providing our people with optimal working conditions and consider employee health and safety an absolute priority. And we always strive to ensure that we protect not only our employees but also our sub-contractors and guests.

Training and awareness-raising

In 2019, the Group launched a Workplace Safety Charter This charter sets out all of Elior's workplace safety commitments and has been issued in all of our host countries.

Vigilance at the highest level of the Group

Data related to employee health and safety (frequency and severity of workplace accidents, etc.) is constantly monitored within the Group. Executive Management is particularly involved in this monitoring process, tracking the information on a monthly basis as part of its performance reviews of each Group entity. During the performance review meetings examples are presented of situations that can cause accidents and the remedial measures put in place.

The right equipment for the right job

As a Group we make sure we have all of the requisite resources for implementing a range of risk prevention measures. Elior's entities provide all of their employees with the protective equipment they need for their jobs (safety shoes, heatproof gloves, safety cutters, etc.).

Training courses on health and safety are among the most well attended within the Group. In 2019-2020, over 40,000 employees attended at least one health and safety training session in Italy, the UK, Spain, Portugal and India.

The teams in each entity design specific programs adapted to their particular markets and requirements. In France, for example, the supply teams worked on a project to reduce the size of packages received and lessening the loads handled by staff.

As well as face-to-face training courses, the Group also has online learning programs. For instance, in 2019 an online module was deployed to help everyone more easily identify the underlying causes of workplace accidents and put in place the necessary remedial measures.

All of these actions and initiatives illustrate the utmost importance that Elior places on the health and safety of its people, and contributed to improving workplace accident and severity rates in 2019-2020.

Performance indicators

2019-2020

2018-2019

Frequency rate of workplace accidents(a) (b)

23.30

28.34(d)

Severity rate(c)

1.35

1.52(d)

  1. Total workforce (permanent and non-permanent employees, casual workers and seasonal staff).
  2. Number of accidents with at least one day's lost time per million hours worked.
  3. Number of days' lost time due to workplace accidents (with at least one day's lost time) per 1,000 hours worked.
  4. Figure updated following a change in the calculation method used by Elior Services to align it with the Elior Group protocol. Under the new method, lost time not classified by the French social security authorities as due to a workplace accident is no longer taken into account (the figure originally reported for 2018-2019 was 1.65).

No fatal workplace accidents occurred in the Group in 2019-2020.

Elior UK set up a network of Mental Health First Aiders during the year. In the first phase of the project, 12 employees followed training sessions about psychological risks in the workplace. The next phase will entail a communication campaign within the company about mental health and the role of the Mental Health First Aiders so their colleagues will know what they do and how to contact them.

Working time organization

The organization of employees' working time varies depending on the local context of each entity and the markets in which they operate.

To ensure that our employees have a good work-life balance, we make sure we offer attractive and flexible working arrangements (part-time work, working from home, etc.). The Group's entities regularly sign collective agreements on this issue as we know it plays a major role in employee efficiency and motivation (see Section 2.6.5 below, "Labor Relations and Compensation Policy").

At September 30, 2020, part-time employees accounted for 50.7% of the total workforce.

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Corporate Social Responsibility 2

Ensuring Employees' Health, Safety and Development

2.6.3 BUILDING EMPLOYEE SKILLSETS AND ENCOURAGING INTERNAL MOBILITY AND CAREER DEVELOPMENT

At Elior, we place great importance on building the skillsets and employability of our people. The Group's career development measures are structured around three key objectives: strengthening the skills-building culture, encouraging internal mobility and career development, and training.

unprecedented situation caused by the Covid-19 pandemic and its effect on the Group's business levels, we focused on transferring employees to different posts or sites in order to protect as many jobs as possible.

In 2019-2020, the internal recruitment rate for managerial positions was 55.0%.

Strengthening the skills-building culture

In 2019-2020, we focused on implementing our talent management processes in order to strengthen the skills- building culture Group-wide.

Performance and skills development meetings were held and talent reviews organized in all entities and targeted at a wide range of employees so as to:

  • Give employees a better understanding of the Group's corporate strategy and ensure that individual objectives are aligned with that strategy and formally documented, along with each employee's actual performance.
  • Identify employees' satisfaction levels in relation to their job and the Group as well as their career development aims and skills-building requirements.
  • Anticipate job changes and identify and prepare successors.

All of the Group's operating countries now have the same talent management process and use the same system.

Encouraging internal mobility and career development

We encourage our people to evolve within the Group and consider internal mobility and career development as a priority. The Group has set itself the objective of filling 70% of managerial posts through internal mobility by 2025, and the importance we place on this indicator can be seen in the fact that the internal recruitment rate is one of the performance criteria underlying the Chief Executive Officer's variable compensation (see Chapter 3, Section 3.1.6.4, "Tables summarizing the compensation of the Company's directors and officers for fiscal 2019-2020 based on the AMF template").

Employees are informed of vacant posts and there is a special IT system that collates all the Group's job offers in France and the UK. Mobility committees have been set up in several countries, and an in-house applicant will always be selected over an external candidate when both have the same skills and abilities. During 2020, due to the

Building employee skillsets

As part of our career development strategy, we offer our people career-move training programs so they can either upskill in their existing job or learn new skills for another job.

Our training catalogs are regularly updated to factor in new market trends, and the training programs cover a wide range of topics such as food hygiene, workplace health and safety and managerial skills-building. The formats proposed vary depending on the subject matter, target audience and end-purpose of the training and the sessions may take the form of face-to-face learning or online learning and may be organized in groups or one- on-one.

For example, Elior UK has created the Chef School to address the shortage of experienced chefs in the labor market. This nine-month program is split into modules that take place on site and in the classroom and over 50 chefs have been trained since it was launched five years ago. On completing the course, participants obtain the Professional Cookery Level 2 diploma qualifying them to manage the operations side of a restaurant. In 2019-2020, 10 students in Scotland and 14 in the south of England took part in the program. In France, Elior continued its partnership with the prestigious Sciences Po university in Paris, launching the third training course for site managers wanting to move up to the position of sector manager.

We had to postpone some face-to-face training in 2020 due to the Covid-19 situation and related lockdowns, but we continued to develop our employees' skillsets through remote training. In March 2020, the French contract catering business deployed a new online training platform

  • L'Ac@démie by Elior - which all of its employees can access. And Elior North America designed and rolled out four training models concerning the management of Covid-19, each of which was followed by several thousand employees. In Spain, a major online training plan was launched during the country's lockdown, with almost 18,000 online modules followed by the Group's Spanish

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employees, representing over 50,000 hours of online training. In addition, nearly 15,000 employees in Spain

participated in online training about Covid-19 safety measures.

2.6.4 PROMOTING DIVERSITY AND INCLUSION

At Elior we are convinced that the diversity of our teams is a real asset, driving our performance and innovation capacity.

In order to attract and retain talent from all backgrounds, our operating entities develop tools and programs to encourage gender equality, diversity of generations and backgrounds, and inclusion of people with disabilities.

Women in top management

At September 30, 2020, women accounted for over two thirds of the Group's overall workforce and almost half of its managers.

Attracting more women to top management positions is one of the Group's priorities and 55% of the managers

Breakdown of employees by gender (Women/Men)

Board of Directors(a)

hired in 2019-2020 were women. Going forward, we intend to continue our initiatives to promote gender balance in top management positions.

In early 2020, a working group was set up, comprising representatives from Elior's different countries and businesses, in order to look into ways of improving gender parity within the Group. A steering committee was then formed, chaired by Philippe Guillemot and bringing together 10 leaders from a broad spectrum of domains, to draw up gender parity objectives and action plans, based on the findings of the working group. A particular objective is to increase the proportion of women on the Group's management bodies (Group Executive Committee, country-level Executive Committees, Leaders Committee), raising it to between 30% and 40% by 2025 and then 40% to 60% by 2030.

September 30, 2020

4 women/5 men

Executive Committee(a)

3 women/10 men

Leaders Committee(a)

19 women/85 men

Managers

49%/51%

Non-managers

71%/29%

Elior Group

68%/32%

(a)Absolute values

We believe that all of our businesses act as real drivers of

The breakdown of the Group's permanent employees by

social integration and we seek to give everyone a chance.

age group was more or less the same year on year.

In line with this, in 2019-2020 the Group hired over 25,000

people aged under 25 and more than 18,000 over-50s.

Breakdown of employees by age group(a)

September 30, 2020

Under 30

13.6%

30-39

19.5%

40-49

26.6%

50-59

30.4%

60 and over

9.9%

Group total

100.0%

(a) Employees on permanent contracts at September 30, 2020

We run many programs to help our employees integrate within the Group and build their skills. These include numerous training sessions in our different fields of business, as well as training on a particular issue or in a specific domain.

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Corporate Social Responsibility 2

Ensuring Employees' Health, Safety and Development

Helping people with disabilities

Giving employment opportunities to people with disabilities is an ongoing objective for Elior. At September 30, 2020, the Group had 3,511 disabled employees (representing 3.3% of the total workforce).

Our operating entities set up special programs to support the specific needs of employees with disabilities.

In 2019, as part of European Disability Employment Week, the employees at our Tour Egée headquarters building in France were given the opportunity to take part in quizzes,

workshops and information sessions to find out more about hearing and visual disabilities as well as invisible disabilities.

Elior France has created a job retention unit which helps prevent employees having to be laid off if they are declared medically unfit to perform their jobs. In 2019- 2020, the unit provided assistance and advice to 177 employees. Elior France also works with companies in the sheltered sector (Esat1, entreprise adaptée2, etc.) and in 2019-2020, over €500,000 worth of its revenue was generated through projects with the social economy sector.

2.6.5 LABOR RELATIONS AND COMPENSATION POLICY

Labor relations

Elior ensures that the International Labor Organization's fundamental principles and rights at work are respected in all of its operating entities:

  • Freedom of association and the effective recognition of the right to collective bargaining.
  • Elimination of all forms of forced or compulsory labor.
  • Effective abolition of child labor.
  • Elimination of discrimination in respect of employment and occupation.

In view of the diversity of its operations and geographic locations, the Group's labor relations with employee representative bodies are managed at national level or at the level of each individual entity.

In 2005, the Group set up a European Works Council (EWC) covering all of its subsidiaries located in the European Union. The EWC is informed annually about the Group's financial position, business operations, strategic objectives and HR situation.

To improve employees' working conditions and efficiency within the Group, collective agreements are regularly signed by the Group's entities on matters such as working time organization and employee compensation and benefits. Further collective agreements were signed within the Group's various entities in 2019-2020 and numerous multi-year agreements signed in previous years are still in force.

Compensation policy

Elior's compensation policy is designed to ensure that compensation and benefits packages are fair across the Group and that mobility is encouraged between its various businesses. No form of discrimination is tolerated. Compensation surveys are regularly conducted by each operating entity in order to identify market practices and offer attractive packages to employees and job candidates.

  • Établissement et service d'aide par le travail (assistance-through-workentities).
  • Sheltered work associations that enable people with disabilities to have a salaried job in conditions adapted to their specific needs. At least 80% of the production staff employed by these associations in France are disabled.

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2.6.6 HAVING A POSITIVE IMPACT ON LOCAL COMMUNITIES

In line with our aim of helping develop the regions where we operate, one of our key objectives is to provide job opportunities for people who struggle to find employment. To this end we work with local partners (job agencies, not-for-profit organizations etc.) when hiring new employees and reject all forms of discrimination (see Section 2.6.4 above, "Promoting Diversity and Inclusion").

Providing support during the Covid-19 crisis

The Covid-19 crisis and resulting lockdowns exacerbated the difficulties suffered by many already fragile households. Elior Italy donated some 5,000 pre-packed meals - cooked at its Zola Predosa central kitchen - to vulnerable families and people over 65 who were unable to leave their homes. Carried out in collaboration with the Casalecchio di Reno municipal authorities, the aim of this project was to help the town and the not-for-profit organizations working in the region with their aid and support programs for people struggling to make ends meet.

Another example of our support efforts during these difficult times was in France, where Elior, Ansamble and l'Alsacienne de Restauration donated meals to the French Red Cross, a charity that helps people in difficulty both in France and abroad. Some 3,000 cold meals were given to help people in Paris, Lyon, Strasbourg, Marseille, Bordeaux and Rennes. Produced by six central kitchens spread across France, the meals were specially prepared to meet the Red Cross's demand. We were able to rapidly put these actions into place thanks to the agility and commitment of our teams. In Spain, Serunion delivered more than 6,000 kg of food to local charities.

Elior Group Solidarités

Set up in 2017, Elior Group Solidarités is a not-for-profit organization tasked with funding, supporting and promoting our solidarity initiatives in the areas of nutrition, social and professional inclusion, and education.

Chaired by Philippe Guillemot, the Group's Chief Executive Officer, Elior Group Solidarités' main action areas comprise:

  • Funding solidarity projects proposed by Group employees.
  • Allocating education grants.
  • Providing financial aid, equipment and volunteer workers to not-for-profit organizations.
  • Supporting environmental projects.

Every year Elior Group Solidarités launches a call for projects in aid of not-for-profit organizations supported by the Group's employees. Since it was created Elior Group Solidarités has supported over 40 projects in the United States, France, India, Italy and the United Kingdom. One of the projects it supported in 2019-2020 was the Carolina Farm Trust, which helps community farmers and urban farmers in the Charlotte Metro area in the United States. The financial support provided by Elior Group Solidarités will go to the Aldersgate urban farm. This 6.7-acre farm will not only give residents of East Charlotte access to local, fresh and healthy food but will also serve as a hub for community engagement, providing opportunities for people to learn about where their food comes from as well as creating local jobs.. In France, one particular area of Elior Group Solidarités' support work is helping disadvantaged young people. During the 2019-2020 academic year, for instance, it gave grants to 20 students of the Ecole de Paris des Métiers de la Table cookery school to help them buy the equipment needed for their courses such as cooking utensils and workwear.

Helping to drive ecological transition is another area that Elior Group Solidarités is involved in, supporting two not- for-profit organizations specialized in agroecology. The concept of agroecology is to make agricultural models more environmentally friendly, which can therefore make a positive impact on Elior's carbon footprint. The aim of the projects led by the two agroecological organizations supported by Elior Group Solidarités is to reduce pressure on the environment (such as by lowering greenhouse gas emissions and using fewer chemicals), and strengthening the role of biodiversity as a production factor.

Also in 2019-2020, over 300 employees in the Group's French, Spanish, UK, US and Italian entities got involved in the Challenge Against Hunger. This event - organized by the NGO Action Against Hunger - raised funds to improve access to water and sanitation services in Jordan.

Lastly, a support fund was set up during the year for the Elior employees most affected by the Covid-19 crisis. Highly aware of the damaging impacts this crisis could have, Elior decided to set up this fund to provide financial assistance to employees suffering from personal or medical difficulties as a result of the Covid-19 situation.

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2.7 METHODOLOGICAL NOTE

2.7.1 NON-FINANCIAL REPORTING PROCESS

Data collection

In order to ensure that the indicators used across its reporting scope are consistent, Elior Group sends a protocol to all of its operating entities that contains the definitions of all of its non-financial indicators (HR, environmental and social indicators) and the related calculation methods. Updated annually, this document also serves as the basis for the annual review work carried out by the independent third party appointed by the Group to verify its non-financial information. It is available on request from the Company.

The main participants in the Group's non-financial reporting process are:

  • The Group CSR Department, which is in charge of the non-financial reporting process at Group level (defining indicators, collecting data from the operating entities, consolidating the data, etc.). The Group CSR Department ensures that the data is consistent and is the main point of contact for the external auditors.
  • Network of local CSR officers. The data collected from the operating entities is tracked by these CSR officers who make sure it is controlled and consistent. If any major differences are identified an analysis is carried out to explain the difference or make the necessary adjustments.

Reporting tools

The Group's non-financial indicators published in this document were compiled based on several different data collection systems. However, all of the data required for CSR reporting is transmitted to the CSR Department via a single dedicated platform. The data is then consolidated using this platform.

The reported HR data for France is collected from a single reporting tool based on information from a shared payroll system used by the majority of the Group's French subsidiaries (Pléiades). For international subsidiaries and for French companies that do not use Pléiades, HR data is collected via the subsidiaries' own information systems and is reported to the Group CSR Department using a standard reporting template.

After carrying out consistency checks, the Group CSR Department consolidates all of the HR data provided by the companies concerned.

Reporting scope and coverage rate

All of the Group's entities are included in the non-financial reporting scope. However, in order to ensure the quality and reliability of the reported data, the Group may decide not to include certain entities for some or all of the indicators. This is notably the case for newly-acquired companies. When an indicator is calculated for a restricted scope, the coverage rate is stated.

The rules for including and excluding companies from the non-financial reporting scope are as follows:

  • Scope exclusions: companies that were removed from the Group's financial scope of consolidation during a given fiscal year (before September 30) are excluded from the non- financial reporting scope.
  • Scope inclusions: companies that were newly consolidated during the fiscal year (newly- formed or acquired companies) are included in the non-financial reporting scope within a maximum of one year. Contract catering and services sites whose contract with the Group was entered into during the fiscal year are also included in the non-financial reporting scope. In these cases, the reporting period starts from the date on which the contract for the site concerned entered into force.

HR, environmental and social data has been consolidated for all of the Group's entities except for Société Monégasque de Restauration and Elior Luxembourg.

Unless otherwise indicated, the reported data covers the fiscal year from October 1, 2019 to September 30, 2020. Depending on the indicators, the reported figure either represents an annual consolidation of data for the fiscal year as a whole (October 1, 2019 to September 30, 2020) or a snap-shot figure at the end of the fiscal year (September 30, 2020). For Elior North America, the period covered is aligned with the local financial reporting period, i.e. from September 28, 2019 to October 2, 2020.

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The reporting scope for HR indicators in 2019-2020 covers 99.9% of the Group's total workforce, i.e. 105,219 employees. It does not include Elior Luxembourg (70 employees).

The reporting scope for environmental and social indicators for 2019-2020 covers 99.8% of the Group's total workforce and represents 99.8% of its consolidated revenue. It does not include Société Monégasque de Restauration (50 employees) or Elior Luxembourg (70 employees).

Specific methodology for certain indicators

Due to the geographic diversity of the Group's activities and the high number of its restaurants and points of sale (over 22,700), some indicators may not be exhaustive, notably because of the difficulty in collecting the data concerned. The methods used have therefore been adapted to take into account this situation.

HR indicators

Managers

For a Group employee to be classified as a manager, he or she must be responsible for a team (i.e. manage one or more other employees) and/or be responsible for a budget.

In France, employees classified as "cadres" and "agents de maîtrise" are classified as managers.

Training

All of the Group's employees, whether managers or non- managers or on permanent or non-permanent contracts, are included in the training indicators.

The types of training taken into account for the purpose of calculating these indicators are as follows:

  • Face-to-facelearning and online learning.
  • Training given by training centers.
  • Training given by external trainers.
  • Induction training when employees begin a new job.
  • Statutory training courses (e.g. on safety).
  • Training given by employees (both qualified and non-qualified trainers) that meets all the following criteria: use of formal training material; duration of more than one hour; training content aimed at building professional skills.

Only the training hours actually completed by employees are counted and not the number of training hours for which employees sign up. For example, only four days will be counted for an employee who signs up to a five-day training course but only attends for four days.

Internal mobility

The Group considers internal professional mobility to be:

  • A promotion, i.e. a new level of responsibility, such as a non-manager on a permanent contract who moves up to a managerial position.
  • A job move (i.e. a new post or department), with or without a new level of responsibility.

The internal recruitment rate corresponds to the proportion of permanent-contract managerial posts filled via an internal mobility move between July 1, 2019 and June 30, 2020. This indicator is calculated by dividing (i) the number of managers who have changed posts and/or duties (including through a promotion) during the period by (ii) the total number of managerial posts filled during the period through both internal mobility and external recruitment. Since 2019, non-managers who have been promoted from within the Group to a managerial post have been taken into account for the purpose of calculating this indicator.

Workplace accidents

Elior defines a workplace accident as any accident (including fatal accidents) that (i) occurs suddenly during working hours, (ii) causes a bodily injury and (iii) results in at least one calendar day of lost time. All of the Group's employees are included in the calculation of workplace accidents, i.e. employees on permanent and non- permanent contracts, casual workers and interns. Only temporary workers are not included.

The workplace accident frequency rate corresponds to the number of accidents with at least one day's lost time that occurred during a given fiscal period per million hours worked.

The severity rate corresponds to the number of calendar days of absence caused by workplace accidents (excluding days of absence for relapses) per thousand hours worked.

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Absenteeism

Elior considers absenteeism as all unplanned hours of absence (paid or unpaid) for managers and non-managers on permanent contracts.

The leave days taken due to governmental restrictions imposed during the Covid-19 crisis are not included in this indicator. However, in some of Elior's operating countries, such as France, sick leave was granted to parents who had to look after young children who were not at school. These absences have been included in the indicator.

Types of absences included:

  • Workplace accidents with lost time (at least one day).
  • General illnesses.
  • Occupational illnesses.
  • All unauthorized absences.

Environmental and social indicators

Certified products

Elior considers "certified products" to be all food and non- food products that carry a label or certification from an organization such as the FSC, PEFC, MSC (Marine Stewardship Council), Max Havelaar, Rainforest Alliance, EU Ecolabel, CMR, Oeko-Tex, Ecocert, Red Tractor, etc.

The term also includes products that are certified as organic, fair trade, protected designation of origin (PDO), AOC (Appellation d'origine contrôlée) and PGI (protected geographical indication).

Local food produce

The Group operates in various geographic regions and the definition of local food produce differs depending on the country concerned. The term is defined as follows in the following countries:

  • France: produce made in France and consumed no more than 200 km from its place of production.
  • Spain/Portugal: all produce grown or made in Spain or Portugal, irrespective of how far from the place where it is consumed.
  • Italy: all produce grown, produced or processed in Italy and consumed no more than 150 km from its place of production.
  • India: all produce (fruit and vegetables, meat, etc. produced/reared/slaughtered in India, irrespective of where it is consumed.
  • United Kingdom: all food produce made in the UK, which may contain raw materials from foreign countries.
  • United States: all produce consumed less than 200 miles from its place of production.

Sustainable seafood, organic produce and cage-free eggs for Elior India

In order to reflect the expectations of Elior India's external stakeholders (clients, guests and society in general), this entity is not included in the reporting scope for these indicators. This is because to date, none of Elior India's clients have made any requests for organic food, sustainable seafood or cage-free eggs. In addition, the maturity of the Indian supply chain in relation to these issues reflects the current low level of general demand in Indian society.

Water and energy use

Elior operates at many different client sites in France and abroad, where data on water and energy use is often not available. It is therefore difficult for the Group to reliably and globally measure its water and energy use at client sites.

Water use

The method used to calculate this indicator was changed in 2019-2020 to make it more accurate. The water volumes taken into account now only correspond to the water used by central kitchens that is billed directly to the Group. Previously the water used by all sites managed by Elior under a contract were taken into account.

As a result of this change, year-on-year comparisons of water use are not meaningful.

Energy use

The electricity volumes taken into account for this indicator only correspond to the electricity used at Group sites that is billed directly to the Group.

GHG emissions - Carbon footprint assessment

The Group disclosed its GHG emissions indicators for the first time in 2018-2019 and they were subject to an in- depth review in 2019-2020. The emissions included in the Group's carbon footprint assessment were calculated in accordance with the Greenhouse Gas Protocol. The calculations were performed based on data relating to the Group's operations and emissions factors, and extrapolations were carried out when data was not available for certain geographic regions.

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"Scope 1" corresponds to direct emissions related to the combustion of fossil fuels (oil, gas, etc.) used at Group sites as well as those generated by leaks of refrigerants from owned or controlled equipment. For emissions related to the use of gas, only the sites for which the Group holds the energy contract are included. Scope 1 also includes emissions from the Group's vehicle fleet.

"Scope 2" corresponds to indirect emissions related to purchased or acquired electricity.

"Scope 3" corresponds to other indirect emissions (notably from purchases of raw materials, upstream and downstream transport and employee travel). Emissions from the use of electricity and gas at sites where the Group does not hold the energy contract are included in this Scope.

2.7.2 CROSS-REFERENCE TABLE - NON-FINANCIAL PERFORMANCE STATEMENT (NFPS)

INFORMATION REQUIRED IN THE NFPS*

SECTION(S) OF THE NFPS

A description of the Group's business model

1.6, "The Group's Business Model"

2.1, "Corporate Social Responsibility: A Value

Creation Driver"

A description of the main non-financial risks related to the Group's

operations

2.1.3, "Non-Financial Risk Map"

The consequences on climate change of the Group's operations and

2.5.2, "Minimizing the Group's Environmental

use of the goods and services the Group produces

Footprint"

The Group's CSR undertakings in terms of:

-

sustainable development

2.1, "Corporate Social Responsibility: A Value

Creation Driver"

-

the circular economy

2.5, "A Circular Model"

- the fight against food waste and food insecurity

2.5.1, "Reducing Food Waste"

-

animal welfare

2.4.1, "Prioritizing Products from Sustainable

Agriculture"

- responsible, fair and sustainable foodstuffs

2.3, "Promoting a Tasty, Healthy and

Sustainable Diet"

2.4, "Responsible Procurement"

Collective agreements entered into within the Group and their

2.6.5, "Labor Relations and Compensation

impact on its financial performance as well as on employees'

Policy"

working conditions

Information on actions aimed at:

- combating discrimination and promoting diversity

2.6.4, "Promoting Diversity and Inclusion"

- encouraging the integration of people with disabilities

2.6.4, "Promoting Diversity and Inclusion"

- preventing corruption and tax evasion

2.2.2, "Fighting Corruption"

- promoting the respect of human rights

2.2, "Conducting Business Responsibly"

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2.7.3 SUMMARY OF ENVIRONMENTAL AND SOCIAL INDICATORS

SUSTAINABLE INGREDIENTS

2019-2020

2018-2019

% purchases of organic food produce

%

3.2%1

3.7%

% purchases of certified food produce2

%

13.7%

12.9%3

% purchases of local food produce

%

12.7%4

20.0%5

% cage-free eggs

%

9.2%1

9.9%

% responsibly sourced seafood

%

35.7%1

29.4%

% responsible packaging and consumables used

%

17.3%

14.4%6

Number of supplier audits performed*

Number

282

399

* During the fiscal year concerned

HEALTHY CHOICES

2019-2020

2018-2019

% purchases of whole-food and plant-based

%

17.0%

18.9%

ingredients7

% vegetarian recipes

%

19.3%

15.5%

Number of sites that carried out at least one guest

Number

4,041

5,960

satisfaction survey*

Number of nutrition specialists

Number

571

629

Number of hygiene audits performed*

Number

9,747

22,374

Number of product analyses performed*

Number

52,889

76,941

% consolidated revenue from entities testing at least

%

89%

-

one nutritional information tool or system8

* During the fiscal year concerned

A CIRCULAR MODEL

2019-2020

2018-2019

% sites collecting organic waste for reuse/recycling*

%

89.0%9

83.2%9

% used cooking oils reused/recycled10

%

81.0%

84.0%

Water use11

cu.m.

471,823

-

Electricity use12

kWh

79,909,58713

69,865,66314

Total CO2 emissions (scopes 1, 2 and 3)**

TeqCO2

3.23 million TeqCO2

-

% consolidated revenue from entities testing solutions

%

85%

-

to reduce food waste15

* Sites at which the Group is contractually responsible for waste management.

  • The year-on-year comparison with 2018-2019 is not meaningful due to a change in the methodology used to determine this figure (see Section 2.5.2 above, "Minimizing the Group's Environmental Footprint".
  • Excluding Elior India (see Section 2.7.1,"Non-Financial Reporting Process").
  • Excluding Elior North America. This indicator was redefined in 2019-2020 and now only includes food purchases.
    3 Data restated following the update to the definition of the KPI (see footnote 2).
    4 Excluding Elior Portugal.
    5 Excluding Elior North America and Elior Portugal.
    6 Excluding Elior Italy.
    7 Excluding Elior India.
    8 Newly-created indicator in 2019-2020.
    9 Excluding Elior Italy.
    10 Excluding Elior North America.
    11 Definition changed: central kitchens for which the Group is contractually responsible for water supply. 12 Sites at which the Group is contractually responsible for electricity supply.
    13 Excluding Elior India.
    14 Excluding Elior NA and Elior India.
    15 Newly-created indicator in 2019-2020.

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ETHICAL BUSINESS CONDUCT1

2019-2020

2018-2019

Number of information sessions given about ethical

Number

24

-

business conduct

Number of employees having participated in a training

or awareness-raising session about ethical business Number

247

-

conduct

2.7.4 SUMMARY OF HR INDICATORS

EMPLOYEE NUMBERS

2019-2020

2018-2019

Total workforce at September 30

Number

105,2192

110,2673

Breakdown of total workforce by:

Type of contract (permanent/non-permanent)

%

86.5%/13.5%

86.7%/13.3%

Category (managers/non-managers)

13.0%/87.0%

13.0%/87.0%

Gender:

Total workforce (women/men)

%

68.0%/32.0%

68.0%/32.0%

Managers (women/men)

%

48.8%/51.2%

48.9%/51.1%

Breakdown of permanent workforce by age:

Under 30

%

13.6%

15.9%

30-39

%

19.5%

20.1%

40-49

%

26.6%

26.4%

50-59

%

30.4%

28.9%

60 and over

%

9.9%

8.7%

Full time/Part time

%

49.3%/50.7%

47.5%/52.5%

Average seniority (permanent workforce)

Number

7 years

7 years

Breakdown of total workforce by country:

France

%

41.6%

40.8%

Spain

%

18.7%

17.7%

United States

%

14.8%

16.6%

United Kingdom

%

10.5%

11.1%

Italy

%

9.8%

9.3%

India

%

4.2%

4.2%

Portugal

%

0.3%

0.3%

Société Monégasque de Restauration (SMR)

%

>0.1%

>0.1%

Total

%

100.0%

100.0%

  • New indicators
  • Excluding Elior Luxembourg
    3 Excluding Elior Luxembourg.

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NEW HIRES

2019-2020

2018-2019

Total new hires*

Number

92,453

119,901

Breakdown of new hires by:

Type of contract (permanent/non-permanent)*

%

21.6%/78.4%

23.1%/76.9%

Category (managers/non-managers)*

%

3.0%/97.0%

2.9%/97.1%1

Gender (women/men)*

%

74.1%/25.9%

74.2%/25.8%

% women in new hires of managers*

%

54.7%/45.3%

53.5%/46.5%

Age

New hires aged under 25*

Number

25,264

29,034

New hires aged over 50*

Number

18,468

19,270

Total number of new employees due to transfers

Number

4,591

6,964

or changes of operator

*Excluding transfers and changes of operator

DEPARTURES

2019-2020

2018-2019

Total departures*

Number

95,422

118,472

Breakdown of departures by:

Type of contract (permanent/non-permanent)*

%

25.5%/74.5%

23.9%/76.1%

Reason for departures of employees on permanent

contracts*

% voluntary departures

61.1%

65.8%

% involuntary departures

31%

25.2%

% departures for other reasons2

7.9%

9.0%

Reason for departures of employees on non-permanent

contracts*

% voluntary departures

%

2.8%

3.1%

% involuntary departures

%

1.0%

1.0%

% departures for other reasons2

%

96.2%

95.9%

Number of departures due to transfers or changes

Number

5,348

7,921

of operator

*Excluding transfers and changes of operator

WORKPLACE HEALTH AND SAFETY

2019-2020

2018-2019

Frequency rate of workplace accidents with lost time3

23.30

28.34*

Severity rate4

1.35

1.52*

  • Figure updated following a change in the calculation method used by Elior Services to align it with the Elior Group protocol. Under the new method, lost time not classified by the French social security authorities as due to a workplace accident is no longer taken into account (the figure originally reported for 2018- 2019 was 1.65).
  • Figure restated due to an error identified in the methodology used.
  • Departures agreed between the employee and employer (e.g. agreed contract terminations in France) and end of non-permanent contracts.
    3 Number of accidents with a least one day's lost time per million hours worked, for the Group's total workforce (employees on permanent and non-permanent contracts, casual workers and seasonal workers).
    4Number of days' lost time due to workplace accidents (with at least one day's lost time) per 1,000 hours worked (employees on permanent and non-permanent contracts).

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ABSENTEEISM

2019-2020

2018-2019

Absentee rate (total workforce on permanent contracts)1

%

6.5%

5.5%

Absentee rate by employee category (managers/non-

%

3.8%/7.0%

3.0%/6.1%

managers)

TRAINING

2019-2020

2018-20192

Number of employees attending at least one training

Number

59,6293

48,801

course during the fiscal year

Average number of training hours:

Per employee

4.24

4.7

By employee category (managers/non-managers)

5.2/4.04

11.7/3.7

Career development

2019-2020

2018-2019

% internal recruitment for managerial posts5

%

55.0%

54.9%

DISABLED EMPLOYEES6

2019-2020

2018-2019

% employees with a disability at the fiscal year-end

%

3.3%

3.9%

Number of employees with a disability hired during the

Number

396

1,607

fiscal year

1 [Hours of absence of the permanent workforce (for workplace accidents with lost time, general illnesses and occupational illnesses]/[Theoretical number of hours worked by the permanent workforce].

  • Excluding Elior North America.
  • Excluding Elior North America, SMR and Elior France.
    4 Excluding Elior France and SMR.
    5 Excluding SMR
    6 Excluding SMR

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2.7.5 REPORT BY THE INDEPENDENT THIRD PARTY ON THE CONSOLIDATED NON-FINANCIAL PERFORMANCE STATEMENT IN THE MANAGEMENT REPORT

This is a free translation into English of the Statutory Auditor's report issued in French and is provided solely for the convenience of English- speaking readers. This report should be read in conjunction with, and construed in accordance with, French law and professional standards applicable in France.

For the year ended September 30, 2020

To the Shareholders,

In our capacity as Statutory Auditor of Elior Group, appointed as independent third party and accredited by COFRAC under number 3-1048 (scope of accreditation available at www.cofrac.fr), we hereby report to you on the consolidated non-financial statement for the year ended September 30, 2020 (hereinafter the "Statement"), presented in the group management report pursuant to the legal and regulatory provisions of Articles L. 225-102-1, R. 225-105 and R. 225-105-1 of the French Commercial Code (Code de commerce).

Company's responsibility

The Board of Directors is responsible for preparing a Statement pursuant to legal and regulatory provisions, including a presentation of the business model, a description of the main extra-financial risks, a presentation of the policies implemented with respect to these risks as well as the results of these policies, including key performance indicators. The Statement has been prepared by applying the company's procedures (hereinafter the "Guidelines"), summarized in the Statement and available on request from its headquarters.

Independence and quality control

Our independence is defined by the requirements of article

  1. 822-11-3of the French Commercial Code and the French Code of Ethics for Statutory Auditors (Code de déontologie). In addition, we have implemented a system of quality control including documented policies and procedures regarding compliance with the ethical requirements, French professional standards and applicable legal and regulatory requirements.

Responsibility of the statutory auditor appointed as independent third party

Based on our work, our responsibility is to express a limited assurance conclusion on:

  • the compliance of the Statement with the requirements of article R. 225-105 of the French Commercial Code;
  • the fairness of the information provided pursuant to part 3 of sections I and II of Article R. 225-105 of the French Commercial Code, i.e. the outcomes of policies, including key performance indicators, and measures relating to the main risks, hereinafter the "Information."

However, it is not our responsibility to provide any conclusion on the company's compliance with other applicable legal and regulatory provisions, particularly with regard to the duty of vigilance, anti-corruption and taxation nor on the compliance of products and services with the applicable regulations.

Nature and scope of procedures

We performed our work in accordance with Articles A. 225-1et seq. of the French Commercial Code defining the conditions under which the independent third party performs its engagement and the professional guidance issued by the French Institute of Statutory Auditors (Compagnie nationale des commissaires aux comptes) relating to this engagement and with ISAE 3000 (Assurance engagements other than audits or reviews of historical financial information).

We conducted procedures in order to assess the Statement's compliance with regulatory provisions, and the fairness of the Information:

  • We familiarized ourselves with the Group's business activity and the description of the principal risks associated.
  • We assessed the suitability of the Guidelines with respect to their relevance, completeness, reliability, neutrality and clarity, taking into account, where appropriate, best practices within the sector.
  • We verified that the Statement covers each category of

information stipulated in

section

III of

Article L. 225-102-1

governing

social

and

environmental affairs, the respect for human rights and the fight against corruption and tax evasion.

  • We verified that the Statement provides the information required under article R. 225-105 II of the French Commercial Code, where relevant with respect

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to the principal risks, and includes, where applicable, an explanation for the absence of the information required under article L. 225-102-1 III, paragraph 2 of the French Commercial Code.

  • We verified that the Statement presents the business model and a description of principal risks associated with all the entity's activities, including where relevant and proportionate, the risks associated with its business relationships, its products or services, as well as its policies, measures and the outcomes thereof, including key performance indicators associated to the principal risks.
  • We referred to documentary sources and conducted interviews to
    O assess the process used to identify and confirm the principal risks as well as the consistency of the outcomes, including the key performance indicators used, with respect to the principal risks and the policies presented, and
    O corroborate the qualitative information (measures and outcomes) that we considered to be the most important1 and for which our work was carried out on the consolidating entity.
  • We verified that the Statement covers the consolidated scope, i.e. all companies within the consolidation scope in accordance with Article L. 233-16, with the limits specified in the Statement.
  • We obtained an understanding of internal control and risk management procedures the entity has put in place and assessed the data collection process to ensure the completeness and fairness of the Information.
  • We carried out, for the key performance indicators and other quantitative outcomes2 that in our judgment were of most significance:
    O analytical procedures that consisted in verifying the correct consolidation of collected data as well as the consistency of changes thereto;
    • substantive tests, on a sampling basis, that consisted in verifying the proper application of definitions and procedures and reconciling data with supporting documents. These procedures were conducted for a selection of contributing entities3 and covered between 19% and 87% of the consolidated data for the key performance indicators and outcomes selected for these tests.
  • We assessed the overall consistency of the Statement in relation to our knowledge of the company.

We believe that the procedures we have performed, based on our professional judgment, are sufficient to provide a basis for a limited assurance conclusion; a higher level of assurance would have required us to carry out more extensive procedures.

Means and resources

Our work engaged the skills of five people between May and December 2020.

To assist us in conducting our work, we referred to our corporate social responsibility and sustainable development experts. We conducted around twenty interviews with people responsible for preparing the Statement.

Conclusion

Based on our work, nothing has come to our attention that cause us to believe that the non-financial statement does not comply with the applicable regulatory provisions and that the Information, taken as a whole, is not fairly presented in accordance with the Guidelines.

Comments

Without qualifying the conclusion expressed above and in accordance with Article A. 225-3 of the French Commercial Code, we make the following comments:

  • The reporting scope is not consistent across all the social, societal and environmental indicators as certain entities are excluded. In particular, the reporting scope for energy consumption is limited to

11 Qualitative information selected: Elior Services' CSR Policy Impacts+; Elior France partnerships with sector approaches; Actions undertaken to design quality menus in line with guest expectations; Internal career development and mobility policy.

  • Social quantitative information: Total headcount as of September 30, 2020 (split by gender and age); Part/full-time employees, Total number of arrivals; Total number of departures (split by reason); Absenteeism rate; Work-related accident with lost time frequency rate; Work-related accident severity rate; Internal hiring rate for managerial positions.

Environmental quantitative information: Total CO2 emissions (scopes 1, 2 and 3); Percentage of sites sorting bio-waste.

Societal quantitative information: Number of hygiene audits conducted; Percentage of organic food products; Percentage of sustainable disposable packaging; Percentage of plant-based and vegetarian recipes.

  • Selected entities: Elior France and Elior North America (United States).

96 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

Corporate Social Responsibility 2

Methodological Note

sites for which the Group is directly invoiced by energy suppliers.

Furthermore, the financial and non-financial scopes are not formally reconciled by the Group.

  • Without impacting the fairness of the published performance, the reporting periods differ from the Group's fiscal year for the internal hiring rate for managerial positions (3-month gap) and the Elior North America entity (2-day gap).
  • Certain policies are presented exclusively at local level and the related improvement goals are not sufficiently described, which hinders the understanding of the Group's initiatives and commitments.
  • The following indicators present uncertainties that are inherent to the various reporting tools and the configuration methods used within the Group:
    O Accident and absenteeism rates at Elior Services, particularly the assessed number of work-related accidents with lost time, the number of days lost due to work-related accidents and the number of hours of absenteeism.
    • Internal hiring rate for managerial positions at Elior North America, particularly the assessed number of external hirings and the number of internal transfers.
    • Percentage of organic food products at Elior North America, particularly organic food expenditure for the fiscal year.
    • Percentage of vegetarian recipes at Elior India, particularly the total number of recipes and sub- recipes.
  • The method of presenting departures differs between Elior Services and Elior Restauration Collective (inclusion of departures as of September 30) and Elior India (no split by reason).
  • The process for collecting supporting documents for work-related accidents with lost time (Elior Restauration Collective and Elior Services) and vegetarian recipes (Elior France and Elior North America) needs further improvement.

Paris-La Défense, January 8, 2021

One of the Statutory Auditors,

Deloitte & Associés

Frédéric Gourd

Catherine Saire

Partner, Audit

Director, Sustainability Services

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 97

3

CORPORATE GOVERNANCE

3.1

Administrative and management bodies

99

3.1.1

Governance structure

99

3.1.1.1 Management structure

99

3.1.1.2 Chairman of the Board of Directors

100

3.1.1.3 Vice Chairman

100

3.1.1.4 Senior independent director

101

3.1.1.5 Chief Executive Officer

101

3.1.1.6 Deputy Chief Executive Officer

102

3.1.1.7 Honorary Chairman

102

3.1.1.8 Non-voting directors

102

3.1.1.9 Group executive committee

102

3.1.1.10 Group corporate committee

103

3.1.2

Executive Management

1044

3.1.3

Board of Directors

104

3.1.3.1 Members of the Board of Directors

104

3.1.3.2 Operating procedures of the Board of

Directors

121

3.1.3.3 Assessment of the Board's operating

procedures

124

3.1.3.4 Board committees

125

3.1.4

Corporate governance code

134

3.1.5 Restrictions on the Chief Executive Officer's

powers

135

3.1.6 Compensation policies

137

3.1.6.1 Key performance indicators used for calculating the compensation of the

Company's officers

137

3.1.6.2 Compensation policies for the Company's directors and officers to be submitted for

approval at the February 26, 2021 Annual

General Meeting

138

3.1.7 Compensation and benefits paid during or awarded for fiscal 2019-2020 to the company's directors and officers, to be submitted for

shareholder approval at the february 26, 2021

annual general meeting

150

3.1.7.1 Compensation and benefits paid during or awarded for fiscal 2019-2020 to Gilles Cojan,

Chairman of the Board of Directors

150

3.1.7.2 Compensation and benefits paid during or

awarded for fiscal 2019-2020 to Philippe

Guillemot, Chief Executive Officer

151

3.1.7.3 Tables summarizing the compensation of the

Company's directors and officers for fiscal

2019-2020 based on the AMF template

158

3.1.7.4 Summary table of transactions in the Company's financial instruments carried out by members of the Board of Directors from October 1, 2019 through November 30, 2020

(disclosed in accordance with Article 223-26 of

the AMF's General Regulations)

173

3.2

Risk management

174

3.2.1

Operational risks

175

3.2.2

Financial risks

192

3.2.3

IT riks

186

3.2.4

Human resources riks

188

3.3

Employees

192

3.3.1

Compensation policies

192

3.3.2

Labor relations

192

3.3.3

Statutory profit-sharing agreements

193

98 . ELIOR GROUP . UNIVERSAL REGISTRATION DOCUMENT

Corporate Governance - AFR 3

Administrative and Management Bodies

3. CORPORATE GOVERNANCE - AFR

Board of Directors' Report on Corporate Governance

In application of Article L.225-37 of the French Commercial Code, the main purpose of the Board of Directors' report on corporate governance is to provide information on the following:

  • The membership of and conditions for preparing and organizing the work of the Board of Directors and the Board Committees.
  • The restrictions on the powers of the Chief Executive Officer.
  • The compensation of the Company's directors and officers that will be submitted for shareholders' approval at the Annual General Meeting of February 26, 2021, notably the compensation policies for fiscal 2020-2021 and the components of the compensation and benefits paid during or awarded for fiscal 2019-2020.

This report was drawn up by the Board of Directors after consulting the members of the Executive Committee and representatives of the Group's various corporate functions. It was reviewed by the Audit Committee on November 23, 2020, presented to the Board of Directors on December 16, 2020 and approved by the Board on January 8, 2021. It will be presented to the Company's shareholders at the next Annual General Meeting on February 26, 2021.

For all corporate governance matters, the Company refers to the AFEP-MEDEF Corporate Governance Code for listed companies, as revised in January 20201 (the "AFEP-MEDEF Code"), and to the recommendations issued by France's securities regulator, the Autorité des Marchés Financiers (AMF). In accordance with the "Comply or Explain" rule provided for in Article L. 22-10-10 of the French Commercial Code and referred to in Article 27 of the AFEP-MEDEF Code, the Company hereby states that it believes its corporate governance practices comply with the recommendations contained in the AFEP-MEDEF Code2.

The Company's Bylaws (the "Bylaws") and the Board of Directors' Rules of Procedure (the "Rules of Procedure") are available on the Company's website3.

3.1 ADMINISTRATIVE AND MANAGEMENT BODIES

3.1.1 GOVERNANCE STRUCTURE

3.1.1.1 Management structure

The Company is a French société anonyme (joint-stock company) with a Board of Directors. The two roles of Chairman and Chief Executive Officer have been separated since November 1, 2017 with a view to enabling the Company's corporate governance bodies to function more effectively.

As at the date of this Universal Registration Document, Gilles Cojan holds the position of Chairman of the Board of Directors and Philippe Guillemot is Chief Executive Officer.

Best corporate governance practices are reflected in the Board's membership structure and operating procedures,

the skills and ethics of the Board's members and the active role that the Board and its committees play in determining the Group's strategy and approving major decisions, as illustrated by the following:

  • Over 50% of the Board's members are independent directors (excluding the employee representative directors), in accordance with the commitments given by the Company and the recommendations of the AFEP-MEDEF Code.
  • Two thirds of the members of the Audit Committee, including its chair, are independent directors and none of its members are executive directors.
  • The majority of the members of the Nominations Committee (excluding the employee representative
  • Code available on the AFEP and MEDEF websites.
  • Exceptions are set out in Section 3.1.4 of this chapter, "Corporate Governance Code".
    3 https://www.eliorgroup.com/elior-group/governance/board-directors

UNIVERSAL REGISTRATION DOCUMENT. ELIOR GROUP . 99

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Elior Group SA published this content on 15 January 2021 and is solely responsible for the information contained therein. Distributed by Public, unedited and unaltered, on 18 January 2021 13:29:01 UTC