Ethics and Integrity

"Integrity to me is living our values through our actions, behaviours and decisions and having the character and courage to do what is right."

Dominic Blakemore
Group Chief Executive Officer

Doing what is right

Compass is committed to upholding high standards of ethics and integrity (E&I) throughout its businesses, a commitment which has earned Compass recognition as a global leader and trusted partner. We believe in responsible leadership and aim to set the standard and act as a role model for ethical behaviour. Our caring, winning culture fosters a thriving workplace where people can confidently make their voices heard. Our values, commitments, global Code of Business Conduct (CBC) and Business Integrity Policy (BIP) guide the decisions, actions and behaviours of our people and serve as a foundation for the way we conduct business with our clients, suppliers, business partners and the communities in which we operate.

Our E&I Programme:

Our programme activities contribute to providing the conditions and requirements for Compass’ employees and those who act on behalf of our company to ensure business is conducted in an ethical, fair and responsible way. Our global Ethics and Integrity programme includes clear policies, procedures and controls to help everyone prepare, prevent, detect and respond to any inappropriate behaviour.

Our approach

is risk-based that centres around creating awareness of business integrity risks and red flag spotting.

We prioritise efforts and programme activities aligned to risk assessments, analytical trends and insights through responsible leadership to promote and maintain a strong tone from the top at country, regional and Group levels.

Governance and Oversight

As part of Compass Group PLC’s governance model, the Corporate Responsibility Committee oversees the Ethics & Integrity programme, including activities and strategy led by the Group Head of Ethics and Integrity and a team of specialists.

Board committees also monitor programme implementation, continuous improvement, business integrity risk management, and internal controls under the Audit Committee and Corporate Responsibility Committee terms of reference.

Complementing this governance structure, our Code of Business Conduct and Business Integrity Policy carry the personal endorsement of the Group CEO, with their implementation and core integrity principles embedded and reinforced through Compass’ global Ethics and Integrity Programme.

Let integrity be your guide. Always

Ethisphere, a global leader in defining and advancing the standards of ethical business practices, announced in November 2025 that Compass Group has earned the coveted Compliance Leader Verification for 2025, 2026 and 2027. The Compliance Leader Verification process involves a rigorous review of an ethics and compliance program and corporate culture. It includes completing the Ethics Quotient® (EQ), a questionnaire covering the elements of an effective program; benchmarking program practices against the World’s Most Ethical Companies®; and extensive document review and interviews with executives and stakeholders.

Compass Group’s performance was evaluated on six key areas: program resources and structure; perceptions of ethical culture; written standards; training and communication; risk assessment, monitoring and auditing; and enforcement, discipline, and incentives.

“Integrity at Compass is a shared responsibility that’s woven into everything we do. Being recognized by Ethisphere with the Compliance Leader Verification award is a testament to our teams’ commitment to openness, trust, and accountability. This award reflects how our values drive us to deliver for all our stakeholders with purpose, while raising the bar for compliance leadership in our industry.” - Stephen Storey, Group Head of Ethics & Integrity

Read the Ethisphere press release here.

Our Priorities for the year ahead:

We embrace a continuous improvement approach and remain agile, adjusting programme activities in response to emerging or identified business integrity risks, including remediation, to prevent reoccurrence in the event of an instance of non-compliance.

For the year ahead, we have prioritised:

Strengthening our assurance framework.
Implementing minimum reporting standards under the Group Data Privacy Policy across all markets.
Continue to strengthen and embed our Third-Party Integrity Due Diligence programme.
Advancing the rollout of our Programme Implementation Playbook (PIP) to ensure consistent compliance standards.
Improving data-driven monitoring and root cause analysis processes.
Leverage new compliance technology and AI capabilities.

Our Ethical Climate

At Compass Group, we build integrity into everything we do through a structured training journey. It begins with Foundations, our new-starter training for leaders, setting clear expectations aligned with our Code of Business Conduct. Each year, we deliver Annual Training focused on emerging integrity risks to reinforce ethical decision-making. We conclude with the Compass Group Annual Pledge and Declaration, where employees across the Group confirm understanding, disclose conflicts of interest, and commit to our values.

Through communication, awareness and training, we empower, encourage and equip our people to spot red flags and make well informed integrity-driven decisions. Our training population includes all Legal, Sales, Finance, People, Internal Audit, Procurement, Growth and Retention teams in addition to our Board of Directors and executive management, leadership and above-unit manager roles at Group, region and country-level.

2025 Key Highlights

Our Annual Training focused on key business integrity risks such as anti-bribery, data privacy, theft and fraud, anti-competition, conflicts of interest and human rights. Through practical examples we encouraged leaders from around the business to spot red-flags, make integrity-led decisions and speak up where needed.

21,000+

employees across the globe completed Annual Training.

Our E&I&U Campaign celebrated local E&I Ambassadors globally. After annual training and a pulse survey, employees self-elected to join this global community, taking on a voluntary role to help continue fostering ethics and integrity locally. Awareness initiatives recognized their contributions through leader-led communications and engagement, reinforcing the importance of ethical leadership at every level.

10,000+

employees self-elected to be E&I Ambassadors.

Compass’ Ethical Climate draws from five questions in E&I’s Pulse Survey* embedded within Annual training, which focus’ on views and perceptions from our risk-to-role training population.