Political Contributions Policy

• Corporate Political Contributions
• US Political Action Committee
• Employee Political Activity
• Contributions to Trade Associations
• Compliance and Oversight

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. For example, in the United States 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 US 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 US senior executives. The company does not retaliate against 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 US 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 US 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. However, as stated in our policies, employees will not be reimbursed by the company directly or otherwise through compensation increases for personal contributions or expenses.

The company belongs to trade associations to which the company pays annual dues. The company does not make contributions to trade associations for the purpose of political contributions.

The Managing Director of Government Relations is responsible for political activities and compliance, working with the company’s internal and external legal counsel where appropriate, and subject to oversight by the company’s General Counsel, Secretary and Chief Compliance Officer. Government Relations periodically updates the Audit Committee of the Board of Directors on the company’s political activities.