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02

COMPLY WITH
LAWS
We comply with all laws, whether local, national or regional. Accenture people, and those acting on our behalf, are responsible for understanding the applicable rules and must work with Legal to ensure compliance. Violations of law can result in significant harm to Accenture, including financial penalties, denial of government contracting privileges, imprisonment for criminal misconduct and damage to our business relationships and reputation.

There are seven ways to make sure your comply with laws.


Anticorruption

Includes: Bribery, Gifts and entertainment, Public Officials, Business Intermediaries


Anti-money laundering

Includes: Financial crime, Escalating red flags, Reporting suspicious activity


Competing fairly

Includes: Interactions with competitors, Bid rigging, Price fixing, Market allocation, Confidential information


Data privacy

Includes: Personal Data


Government compliance

Includes: Government bidding and contracting, Procurement regulations


Trade compliance

Includes: Economic sanctions, Export controls, Reviewing business opportunities


Insider trading

Includes: Material and non-public information, Tipping, Black-out periods

Anticorruption


We do not give or accept bribes—including inappropriate gifts or entertainment—and
we get approval before offering any gifts or entertainment to Public Officials.

WE COMPLY WITH ANTICORRUPTION LAWS WITHOUT EXCEPTION


Accenture's stance on corruption, sometimes referred to as bribery, is very simple: Corruption is wrong, it is against the law and we don’t give or accept bribes.


We comply with anticorruption laws—without exception, regardless of local business culture or practices. Even if our competitors give bribes or make questionable payments, Accenture has zero tolerance for bribery or any other activity that violates these laws.

DO NOT GIVE OR ACCEPT BRIBES


We pride ourselves on our relationships with our clients and understand that cultivating those relationships often is best accomplished in social settings—such as meals, sporting events or other forms of entertainment. While ordinary relationship-building activities—including gifts and entertainment—can be appropriate, we must also remain vigilant to ensure nothing we do could create even an appearance of impropriety.


Bribes are “anything of value” intended to secure an improper advantage or otherwise inappropriately influence the recipient. This means anything that is valued by the person that someone is attempting to influence—whether or not it has any commercial value. It does not matter whether the thing of value is funded by Accenture, a third party or from the employee’s own personal resources. Merely offering something of value can violate the law, whether or not it is actually accepted or a benefit is received.

DO NOT GIVE INAPPROPRIATE GIFTS OR ENTERTAINMENT


Under anticorruption laws, it is illegal to offer or give gifts or entertainment if done with a corrupt intention. A corrupt intention means that the goal in giving the gift or entertainment is to influence someone to misuse their position in order to benefit Accenture.


APPLY OUR 5 GIFTS AND ENTERTAINMENT CRITERIA


Before providing or accepting any gift or entertainment, apply our five gifts and entertainment criteria (5 G&E Criteria) to confirm that it is:


  1. For a proper purpose and not intended to secure an improper advantage or otherwise inappropriately influence the recipient

  2. Permitted by law

  3. Permitted by our policies

  4. Permitted by the recipient’s policies and by any agreements between Accenture and the recipient’s employer

  5. Reasonable in value and appropriate under the circumstances


Many companies and governments have policies about what their employees may accept, and sometimes our contracts with clients or other parties specifically limit or forbid us from providing gifts or entertainment to their employees. Because of this, review and confirm that the recipient’s policies and contracts with Accenture allow us to give a gift or entertainment before offering it.

GET APPROVAL BEFORE PROVIDING ANY GIFTS OR ENTERTAINMENT TO PUBLIC OFFICIALS


Providing a gift or entertainment to a “Public Official” is permissible if the gift or entertainment meets our 5 G&E Criteria—and—the gift is approved through our Gifts & Entertainment Tool. Public Officials (which include family members) are generally government employees or employees of organizations partially or wholly owned by a government.

We do not use or allow third parties to give bribes or make questionable payments on our behalf,
which is why we only work with approved Business Intermediaries—companies or individuals
that we expect to interact with our clients or represent Accenture before a government body.

CAREFULLY REVIEW BUSINESS INTERMEDIARIES BEFORE ENTERING
INTO BUSINESS WITH THEM


Because Accenture can be held responsible for bribes given by third party “Business Intermediaries” on Accenture’s behalf—even if we did not approve or know of their actions—we carefully review potential Business Intermediaries before entering into business with them. To ensure we only work with reputable individuals and companies, we conduct due diligence on all Business Intermediaries prior to engaging them and repeat this process regularly for those individuals and companies with whom we have a long-term relationship.

We follow Accenture’s procedures on interacting with Public Officials
and rules regarding political contributions and campaign activities.

FOLLOW ACCENTURE’S PROCEDURES ON INTERACTING WITH PUBLIC OFFICIALS


Employees who interact with Public Officials, or who supervise others who do, must understand and abide by our procedures as well as the laws governing lobbying and contact with Public Officials, political contributions and campaign activity. As a general rule, refrain from activities that could place Accenture’s name in a partisan political posture.


FOLLOW ACCENTURE’S RULES REGARDING POLITICAL CONTRIBUTIONS AND CAMPAIGN ACTIVITIES


To avoid the appearance of impropriety or to prevent conflicts of interest, we prohibit corporate political contributions (both monetary and in-kind) to political candidates, political parties or party committees on behalf of Accenture and its clients.


Anti-money Laundering


We do not engage in any money laundering or terrorist financing activities
or assist any other party in doing so, we escalate any red flags that we identify
for further investigation and we report suspicious activity
to the government where required.

DO NOT ENGAGE IN ANY MONEY LAUNDERING OR TERRORIST FINANCING ACTIVITIES OR ASSIST ANY OTHER PARTY IN DOING SO


Accenture has zero tolerance for financial crime. This includes money laundering and terrorist financing. Accenture’s most effective tool for detecting red flags is you.


Accenture is at a higher risk of being exposed to money laundering and terrorist financing activities when we:


  • Handle funds or process financial transactions or applications on behalf of clients

  • Conduct business in countries where there is little enforcement of laws prohibiting money laundering and terrorist financing activities

  • Conduct business in countries where financial transparency standards (e.g., bank secrecy) make it easier to hide these activities, and therefore they are more widely prevalent


Money laundering and terrorist financing are linked because terrorism is more often funded by money or assets that were obtained illegally, but then laundered to appear as if they came from a legitimate business.

ESCALATE RED FLAGS FOR FURTHER INVESTIGATION AND REPORT SUSPICIOUS ACTIVITY TO THE GOVERNMENT WHERE REQUIRED


If you identify a red flag, you are required to follow these three steps:


  1. Escalate the red flag to your management, Human Resources or Legal or to the Accenture Business Ethics Helpline. If employed by, or providing services on behalf of an Accenture Regulated Company, escalate to your Anti-Money Laundering (AML) Compliance Officer. Even if you are not 100% sure the activity you identify is a red flag, raise your concerns.

  2. If the red flag is part of a transaction or other approval process you perform, you must place the transaction or approval process on temporary hold.

  3. Avoid notifying or “tipping off” clients or any other party that you are aware of potentially illegal activity as this is illegal in some countries.

Competing Fairly


We do not collaborate with competitors on how to price our services or whether
to pursue opportunities in a particular market.

WE ARE FIERCE BUT FAIR COMPETITORS


Accenture only pursues and wins business on the merits. Do not engage in conduct that gives even the appearance of unfair competition.


Do not collaborate or agree with a competitor about pricing of services or offerings, or timing of planned price increases or target margin changes. These practices are commonly called bid rigging or price fixing and violate competition laws.


Do not divide opportunities, markets, offerings or geographic regions. These practices are commonly called market allocation agreements, and they also violate competition laws.


If approached by a competitor about anything prohibited, make it clear that we are not agreeing to anything and do not want their confidential information. End contact with that person immediately and contact Legal as soon as possible.

We do not misuse the confidential information of our competitors, business
partners, clients, suppliers or former employers.

DO NOT SHARE ACCENTURE’S CONFIDENTIAL INFORMATION WITH A
COMPETITOR, AND DO NOT ACCEPT A COMPETITOR’S CONFIDENTIAL INFORMATION


While the Accenture Way is to collaborate and share, we must do so within appropriate limits. Do not share Accenture’s confidential information with a competitor, and do not accept a competitor’s confidential information. When joining Accenture, do not take any documents from former employers or share that employer’s confidential information. Do not ask other employees to share confidential information from their former employers.


We respect the obligations new people bring. We respect valid and enforceable obligations that candidates and new employees may have to former employers, such as confidentiality obligations or agreements not to compete or to solicit former clients or colleagues. We expect new Accenture people to be aware of these obligations and to notify their supervisors immediately if a job activity may conflict with those obligations.

Data Privacy


We process and protect personal data in compliance with data privacy laws.

COMPLY WITH DATA PRIVACY LAWS


We comply with data privacy laws when collecting and processing personal data, including as it relates to our own people and our clients. Data privacy laws also give rights to individuals regarding their personal data.

We process personal data fairly and lawfully and provide access to personal data within our organization only on a need-to-know basis. When someone provides us with their personal data, we tell them who is collecting/using the data, the intended use and respect their individual rights to the data, including access and correction.


We do not re-use personal data for other purposes incompatible with the intended use, and we minimize and anonymize data collection where feasible. Accenture maintains retention policies and procedures; when we no longer need to keep personal data, we destroy it. We maintain organizational, physical and technical security arrangements for the personal data we hold.


Accenture recognizes that security is important when arranging for outside service providers to process personal data on our behalf (“data processors”). We ensure data processors are bound by contract to process data only as instructed, and maintain appropriate data protection security arrangements.


We follow Accenture’s procedures to deal with any suspected breach of data security arrangements, unauthorized access or disclosure or loss of personal data.

Government Compliance


We obtain all required approvals to provide services to government clients and comply with government contracting and procurement regulations.


KNOW HOW TO DO BUSINESS WITH GOVERNMENTS


The meaning of “government” is broad. Government clients may include traditional government agencies as well as commercial for-profit entities that are controlled or owned by governments (even partially owned). Doing business with governments is very different from doing business with commercial clients.


Because doing work for government entities often carries legal and other risks, we obtain all required approvals before pursuing opportunities to provide services to government or government-owned clients. We understand and comply with the legal requirements and restrictions that apply to bidding, pricing and delivering our services to government clients.

Trade Compliance


We comply with all applicable international trade controls—including economic
sanctions and export controls—and we review all business opportunities to ensure compliance.

COMPLY WITH ALL APPLICABLE INTERNATIONAL TRADE CONTROLS, INCLUDING ECONOMIC SANCTIONS AND EXPORT CONTROLS


International trade controls are laws that govern the cross-border transfer of goods, technology and services. These laws include economic sanctions, which are legal measures that restrict where and with whom we can do business; and export controls, which are laws that impose special legal requirements like government licensing on the international transfer of certain goods, technology and services. Export controls often apply in connection with highly regulated industry sectors like aerospace and defense and nuclear power generation, or software with advanced data encryption capabilities.


As international trade controls may change over time, we are responsible for understanding the applicable policies and working with Legal to ensure compliance. International trade controls do not impose any special requirements on the cross-border transfer of ordinary consumer items available to everyone in the retail marketplace, unless a prohibited country, organization or individual is involved in the transfer. Things we use every day like office supplies, or laptops and devices with standard software and applications, generally are not restricted by international trade controls.

REVIEW ALL BUSINESS OPPORTUNITIES TO ENSURE COMPLIANCE WITH INTERNATIONAL TRADE CONTROLS


Document all business opportunities in Manage my Sales (MMS) as part of the normal Accenture opportunity management process by answering four international trade control screening questions.


Use the Export Compliance and Tracking Tool (ECATT) to help identify when we must comply with any special legal requirements, such as obtaining a government-issued license before transferring items restricted by trade controls from one country to another, or to a person from another country.

Insider Trading


We do not engage in insider trading or tipping others with respect to inside information
and we comply with restrictions on trading Accenture shares during black-out periods.

DO NOT ENGAGE IN INSIDER TRADING OR TIPPING OTHERS WITH RESPECT TO INSIDE INFORMATION


Do not trade on or disclose inside information. Do not buy or sell Accenture securities (or the securities of a client or other party) when in possession of inside information or provide such information to others, until it officially becomes public. Also, obtain required approvals before trading in the securities of a client (e.g., when working on a project for that client).


Inside information is information about Accenture, our clients or other parties that is "material" and "nonpublic." Information is material if it could affect the price of a security, or if a reasonable investor would likely consider it important in deciding whether to buy or sell securities.


Information is nonpublic if it has not been made available officially (e.g., through an SEC filing or a press release) and effectively to the general public (meaning sufficient time has passed—generally considered two trading days—to allow markets to absorb the information).


Do not tell others to buy or sell securities or provide "tips," either in the form of details, such as "our third-quarter earnings next week will be great" or as general comments, based on nonpublic information.

COMPLY WITH RESTRICTIONS ON TRADING ACCENTURE SHARES DURING BLACK-OUT PERIODS


Accenture Leaders, members of the board of Accenture plc and others identified by Accenture as having routine access to inside information are prohibited from trading in any Accenture shares during black-out periods.