Political Contributions and Lobbying Policy

• Lobbying
• Trade Associations
• Corporate Political Contributions
• U.S. Political Action Committee
• Employee Political and Civic Activity
• Compliance and Oversight

From time to time we engage in discussions with all levels of governments on public policy issues. When we determine it is in the best interest of our company, we work with governments to provide information and perspective that support our point of view. The company discloses its lobbying activity and expenditures as required by law. All United States federal lobbying costs and the issues to which they relate are disclosed in the United States under the Lobbying Disclosure Act, which requires that we file reports on a quarterly basis with the United States Congress; these reports are publicly available at: http://www.senate.gov/legislative/Public_Disclosure/LDA_reports.htm.

The company participates in trade associations for a variety of reasons, including networking, building industry skills, civic participation and monitoring of industry policies and trends. Company participation in trade associations, including membership on a trade association board, does not mean that the company agrees with every position a trade association takes on an issue. In fact, from time to time our corporate positions may differ from those of the trade association of which we are members.

The company makes payments to these associations, including membership fees and dues. The company’s policy is to instruct U.S. trade associations not to use company funds for independent campaign expenditures or contributions to state and local ballot measures, non-candidate organizations (such as political convention host committees) or organizations organized under Section 527 of the Internal Revenue Code.

The company has a longstanding global policy against making contributions to political parties, political committees or candidates using company resources (including monetary and in-kind services), even where permitted by law. As a result, in the United States for example, the company is prohibited from using company resources to make independent campaign expenditures, or to contribute to state or local ballot measures, non-candidate organizations (such as political convention host committees) or organizations organized under Section 527 of the U.S. Internal Revenue Code.

In the United States, Accenture maintains a political action committee (PAC) that is registered with the Federal Election Commission (FEC). The PAC makes Federal political contributions on a bipartisan basis to political parties, political committees and candidates. The PAC is not funded by corporate funds, but is fully funded by voluntary contributions made by our U.S. senior executives. The company does not penalize in any way senior executives who do not contribute to the PAC.

The PAC complies with all applicable laws concerning political contributions, including laws requiring public disclosure of such contributions. As permitted by law, corporate funds and facilities are used to provide administrative support for the PAC, including for the solicitation of contributions and the distribution of funds. All contributions made by the PAC are reported in filings with the FEC and are publicly available on the commission’s website. All PAC donations are also disclosed to the U.S. Senate and House of Representatives in the company’s semi-annual filings required by the Honest Leadership and Open Government Act.

The PAC is managed by the Office of Government Relations (Government Relations), headed by a Managing Director who is a member of our United States Leadership Team. Government Relations approves all PAC contributions.

All PAC activities (including solicitation of senior executives and contributions to parties and candidates) are governed and overseen by its governing body, the PAC Committee, which includes senior leaders from across the company’s U.S. business.

The company’s employees have the right to participate in the political process by making personal contributions from personal funds, subject to applicable legal limits and requirements and our Code of Business Ethics. In addition, as stated in our policies, employees will not be reimbursed by the company directly or otherwise through compensation increases for personal contributions or expenses.

Employees may voluntarily participate in campaign activities but must do so on their own time, or by taking paid time off or an unpaid leave of absence. In situations where our employees wish to enter public service, the company has policies in place to avoid conflicts of interest.

The Managing Director of Government Relations, General Counsel, Country Managing Directors, and Operating Group Chief Executives where appropriate, have oversight over political, lobbying, advocacy and compliance activities, working with the company’s internal and external legal counsel as required. The Managing Director of Government Relations periodically updates the Audit Committee of the Board of Directors on the company’s political, lobbying and other advocacy activities and U.S. Political Action Committee.