FINAL ASSESSMENT ACCENTURE PLC - …companies.defenceindex.org/pdf/accenture_xml.pdf · ACCENTURE...

ACCENTURE 20/12/2014 WWW.ACCENTURE.COM

FINAL ASSESSMENT

ACCENTURE PLC

The following pages contain the detailed scoring for your company based on

public information.

The following table represents a summary of your scores:

Topic Number of

questions

% score based on

public information

Leadership, Governance and

Organisation

10 75%

Risk Management 5 40%

Company Policy and Codes 12 75%

Training 5 60%

Personnel and Helplines 7 71.4%

Total 39 67.9%

TI has found no evidence that the company is involved in offsets and has therefore removed the two relevant

questions (A13a and A13b)


A1:

Does the company publish a statement from the Chief Executive Officer or the Chair of the Board supporting the ethics and anti-corruption agenda of the company?

Score:

1

Comments:

Based on public information, there is evidence that the company has published a statement from CEO and Chairman Pierre Nanterme in the last two years, which promotes the company’s ethics and anti-corruption agenda. Other statements found in a 2013 letter and the 2010-2011 Corporate Citizenship Report are assessed to be insufficient, due to their breadth and strength. The company therefore scores 1. To score higher the company would need to provide evidence of two more CEO statements from the last two years that support the ethics agenda of the company, or a single CEO statement from the last two years that specifically supports the company’s stance against corruption.

References:

Public:

Code of Business Ethics, 2014, p.5:

‘At Accenture, we do things in a unique way … the Accenture Way. It is the way we innovate, collaborate, operate and deliver value—for our clients and our shareholders. And it is grounded in our core values, shared business ethics and uncompromising standards for high performance.

Indeed, the Accenture Way is embedded in our Code of Business Ethics, which establishes an ethical framework of expected behaviors in everything we do: from serving our clients and running our business, to further enhancing our brand, reputation and transparency as a company.

At the heart of our Code of Business Ethics are our six enduring core values: Client Value Creation, One Global Network, Respect for the Individual, Best People, Integrity and Stewardship. The Code of Business Ethics also includes action statements that describe how we can fully embrace our values and meet the obligations that each of us must understand and follow to maintain an ethical workplace.

We take great pride that Accenture is repeatedly recognized externally for our commitment to ethical leadership, compliance practices and corporate social responsibility. To continue


to be a model in this area, it is our collective responsibility to read our Code of Business Ethics and have the knowledge to operate as an ethical company.

The Accenture Way demands a high standard from each of us every day, in everything we do. I appreciate all you continue to do to represent our Code of Business Ethics and the core values that make Accenture the special company it is.’

Message from the CEO

http://www.accenture.com/us-en/company/governance/ethics-code/Pages/index.aspx

2013 Letter from Our Chairman & CEO

http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-2013-Letter-from-Our-Chairman-and-CEO.pdf

‘In addition, Accenture upholds the highest standards of integrity, compliance and ethics, and for the sixth consecutive year, the Ethisphere Institute named us one of the “World’s Most Ethical Companies.”

2010–2011 Corporate Citizenship Report Summary, 2012: 2

http://unglobalcompact.org/system/attachments/14748/original/Accenture_CCR2011.pdf?1333140258

‘We have put in place a number of new policies and practices to ensure that all of our employees, contractors and suppliers follow the highest ethical standards. For example, our refreshed Code of Business Ethics includes 58 "action statements" that synthesize the conduct we expect of our employees and our leadership.’

Letter from Pierre Nanterme, CEO and Adrian Lajtha, Chief Leadership Officer

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-governance/Pages/leadership-and-corporate-citizenship-governance.aspx

‘Our Chairman & CEO plays a key role in establishing tone from the top. He visibly and frequently communicates on two matters: we have zero tolerance for violations of law and for retaliation against employees reporting issues; and a strong ethics and compliance program is an essential part of being a high-performance company and in reaching our goals as a company.’

UN Global Compact: Communication on Progress, 2013, p.19:

‘Our Chairman & CEO plays a key role in establishing tone from the top. He visibly and frequently communicates on these matters. Two primary messages are: (1) we have zero tolerance for violations of law and for retaliation against employees reporting issues and (2) a strong ethics and compliance program is an essential part of being a high-performance company and in reaching our goals as a company.’









A2:

Does the company’s Chief Executive Officer or the Chair of the Board demonstrate a strong personal, external facing commitment to the ethics and anti-corruption agenda of the company?

Score:

1

Comments:

Based on public information, there is no readily available evidence that the company’s CEO or Chairman demonstrate a strong personal, external facing commitment to its ethics and anti-corruption agenda. Despite the CEO representing the company in a number of external venues, there is no evidence to suggest this was in regard to the ethics and anti-corruption agenda of the company. However, there is evidence that such engagement is delegated. For example, General Counsel, Secretary & Chief Compliance Officer Julie Spellman Sweet, was a speaker at the 2012 Global Ethics Summit. The company therefore scores 1. To score higher the company would need to provide evidence that the CEO or Chairman demonstrate a strong, personal, external facing commitment to the company’s ethics and anti-corruption agenda.

References:

Public:

‘Mr. Nanterme represents Accenture in a number of external venues. Since 2011, he has served on various task forces for the B20 Summit, which comprises top business leaders from the G20 countries who inform and advise the G20 on key global issues from a business perspective. He is a member of the World Economic Forum’s International Business Council and chairs its IT Governors Steering Committee. He also serves on the steering board of the European Commission’s European Cloud Partnership and is a member of the Wall Street Journal’s CEO Council.’

http://www.accenture.com/us-en/company/people/pages/pierre-nanterme.aspx

http://westlegaledcenter.com/program_guide/course_detail.jsf?courseId=41535783

Julie Spellman Sweet, General Counsel, Secretary & Chief Compliance Officer was a speaker at the 2012 Global Ethics Summit

UN Global Compact: Communication on Progress, 2011, 16:

http://www.accenture.com/us-en/company/people/pages/pierre-nanterme.aspx

http://westlegaledcenter.com/program_guide/course_detail.jsf?courseId=41535783


‘In March 2010, Accenture’s director of Anticorruption Law participated in a panel discussion on anticorruption compliance at the Corporate Counsel Institute in Washington, D.C.’


A3:

Does the company’s Chief Executive Officer demonstrate a strong personal, internal-facing commitment to the ethics and anti-corruption agenda of the company, actively promoting the ethics and anti-corruption agenda at all levels of the company structure?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company’s CEO demonstrates a strong, personal, internal-facing commitment to its ethics and anti-corruption agenda. TI notes that the company states that its ethics framework has the “visible support of our senior leadership”.

References:

Public:


‘Accenture’s Ethics & Compliance program is designed to (i) foster the highest ethical standards and a commitment to compliance with the law and policy, (ii) prevent, detect, report and address any allegation of misconduct, and (iii) comply with applicable laws and standards.

Accenture has adopted a framework designed to achieve these objectives, which includes (i) visible support of our senior leadership, (ii) regular and periodic risk assessments, (iii) written standards and controls, (iv) ongoing training and communications, and (v) auditing, monitoring, and response procedures.’



A4:

Does the company publish a statement of values or principles representing high standards of business conduct, including honesty, trust, transparency, openness, integrity and accountability?

Score:

2

Comments:

Based on public information, there is evidence that the company has a statement of values representing high standards of ethical business conduct, including integrity. This value is explained thoughout the company’s website and documents, with the Code of Business Ethics clearly demonstrating why it is important to the company and how it is translated into its policies. The company also references trust, honesty and accountability.

References:

Public:

http://www.accenture.com/us-en/company/overview/values/Pages/index.aspx

‘Since its inception, Accenture has been governed by its core values. They shape the culture and define the character of our company. They guide how we behave and make decisions.

Stewardship

Fulfilling our obligation of building a better, stronger and more durable company for future generations, protecting the Accenture brand, meeting our commitments to stakeholders, acting with an owner mentality, developing our people and helping improve communities and the global environment.

Best People

Attracting, developing and retaining the best talent for our business, challenging our people, demonstrating a “can-do” attitude and fostering a collaborative and mutually supportive environment.

Client Value Creation

Enabling clients to become high-performance businesses and creating long-term relationships by being responsive and relevant and by consistently delivering value.

One Global Network

Leveraging the power of global insight, relationships, collaboration and learning to deliver exceptional service to clients wherever they do business.

http://www.accenture.com/us-en/company/overview/values/Pages/index.aspx


Respect for the Individual

Valuing diversity and unique contributions, fostering a trusting, open and inclusive environment and treating each person in a manner that reflects Accenture’s values.

Integrity

Being ethically unyielding and honest and inspiring trust by saying what we mean, matching our behaviors to our words and taking responsibility for our actions.’


‘Operating with integrity every day is the Accenture Way. Accenture’s commitment to doing business ethically and legally is the foundation for the company’s culture, which is shaped by our six core values–Client Value Creation, One Global Network, Respect for the Individual, Best People, Integrity and Stewardship.’

‘The Code of Business Ethics builds on our six core values by providing greater detail about expected ethical behaviors of all employees. The Code of Business Ethics provides this detail through a series of “action statements” associated with each core value that describe how we expect all employees and contractors to behave in relation to specific circumstances.’


http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-Code-Business-Ethics-v12.pdf

‘Our Code of Business Ethics reinforces our core values and drives our culture of compliance, ethical conduct and accountability.

Our core values shape the culture and define the character of our company. They serve as a foundation for how we act and make decisions. Acting with integrity in compliance with laws is not just about doing the right thing and protecting Accenture. It has a tangible impact on our performance and reflects on our character as a business—to our clients, our business partners and the public at large. It provides us the freedom to expand our operations around the world and generate new business opportunities, differentiating us from our competitors as our clients demand ever higher standards, and strengthening our brand and reputation.

Our company commitment to our core values and ethical conduct is important, but the personal commitment of every employee is critical to make this commitment effective.’

(p.4): ‘Our Code of Business Ethics starts with a simple proposition—we always act with integrity and we always act in compliance with the law. It represents the one place that incorporates all of Accenture’s ethical principles into a single resource available both to Accenture people and the public at large.

The Code of Business Ethics builds on our six core values by providing greater detail about expected ethical behaviors of all employees. The Code of Business Ethics provides this detail through a series of “action statements” associated with each core value that describe how we expect each other to behave in relation to specific circumstances.’





(p.6): ‘Our Code of Business Ethics: Our Core Values in Action shows how to “live” our core values so that each of us can help drive Accenture’s success. It describes in practical terms how to apply our core values every day. Through “action statements,” it captures what we must do to comply with the law, as well as Accenture policies and practices.’

(p.8): ‘Integrity in action Being ethically unyielding and honest and inspiring trust by saying what we mean, matching our behaviors to our words and taking responsibility for our actions.

1. We create an inclusive and safe environment—one that encourages open debate, gives everyone a voice and enables people to raise issues without fear of retaliation.

2. We build trust-based relationships through consistent ethical personal conduct and by living our core values.

3. We prepare and provide accurate, timely and complete reports for our clients and other stakeholders.

4. We protect our clients’ and others’ proprietary information and respect their intellectual property rights.

5. We avoid actual and perceived conflicts of interest and ensure that our personal and financial relationships and activities do not compromise Accenture’s objectivity or reputation.

6. We do not accept or give inappropriate gifts or entertainment.

7. We refuse to make or take bribes or to make questionable payments.

8. We are fierce but fair competitors.

9. We handle “inside information” appropriately and lawfully.

10. We comply and cooperate fully with investigations, ongoing litigation and audits.

11. We use electronic technology responsibly and professionally.

12. We are respectful and professional when using social mediasites.’

‘Stewardship in action

Fulfilling our obligation of building a better, stronger and more durable company for future generations, protecting the Accenture brand, meeting our commitments to stakeholders, acting with an owner mentality, developing our people, and helping improve communities and the global environment.

1. We do business in a manner that is socially, economically and environmentally responsible.

2. We balance the short-term demands of our business with the long-term needs of the company and make investments to enhance shareholder value.

3. We are entrepreneurial, act as owners of the company, make decisions within our authority and use informed judgment to take appropriate risks.

4. We invest time and resources in preparing our next generation of leaders, while striving to mirror the global and diverse nature of our marketplace.

5. We operate the company so that we achieve high performance generation to generation


as well as from year to year.

6. We expect Accenture people to put the broader interests of the entire company ahead of the individual interests of a group or function.

7. Our leaders communicate and demonstrate a shared vision and a commitment to strategic priorities—helping employees understand how individual roles contribute to our overall success.

8. Accenture is a good corporate citizen and encourages the active involvement of employees in the communities where we work and live.

9. We invest in Accenture’s assets, safeguard Accenture’s proprietary and confidential information, and protect and defend Accenture’s intellectual property.

10. We exercise Accenture’s rights in the political process.’

(p.22): ‘Integrity: Being ethically unyielding and honest and inspiring trust by saying what we mean, matching our behaviors to our words and taking responsibility for our actions.’

‘Our core values guide our actions in all we do. We say openly that our actions are based on our understanding of right and wrong, even if that position is unpopular, and we adhere to our Code of Business Ethics and core values in all circumstances.’

Explains the key behaviours of integrity. For example point 7:

(p.24): ‘7. We refuse to make or take bribes or to make questionable payments.

• We comply with anticorruption laws—period. These laws include the U.S. Foreign Corrupt Practices Act, UK Bribery Act and local anticorruption laws wherever we do business.

• Bribes can be “anything of value,” that is, any inducement regardless of form, such as a gift, a meal, entertainment, travel lodgings, a loan, a promise of employment or a personal favor. 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.

• Our standards may be higher than local business practices. Even if our competitors make bribes or questionable payments, Accenture will not tolerate illegal or unethical conduct.

• We do not offer or give anything of value to obtain new business, retain existing business, expedite government actions or secure any improper advantage. And we do not use others to do things we cannot do.

• We retain only qualified business intermediaries to help sell and deliver our services and products. We hire business intermediaries to help open doors and sell and deliver Accenture’s services only after we have been reviewed and approved under Policy 1327—Business Intermediaries.’

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-governance/Pages/ethics-and-compliance-programs.aspx

‘Operating with integrity links directly to our core values—Client Value Creation, One Global Network, Respect for the Individual, Best People, Integrity and Stewardship. Our efforts to promote ethical behavior have been noticed: 2014 marked our seventh consecutive year on




Ethisphere’s “World’s Most Ethical Companies” list, recognizing our commitment to ethical leadership, compliance practices and corporate citizenship.’


A5:

Does the company belong to one or more national or international initiatives that promote anti-corruption or business ethics with a significant focus on anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company is a signatory to the UN Global Compact and participates in the World Economic Forum’s Partnering Against Corruption Initiative.

References:

Public:

http://www.accenture.com/microsites/corporate-citizenship-report/2014/about-the-report/Pages/un-global-compact.aspx

‘"Our Communities, Our Commitments" follows guidance from the United Nations Global Compact (UNGC), which we signed in 2008, and serves as our fifth Communication on Progress against the UNGC's 10 principles.’

http://www.accenture.com/us-en/company/citizenship/Pages/ungc-indices.aspx

‘Accenture has been a signatory to the 10 principles of the United Nations Global Compact (UNGC) since 2008, and we are one of the 50 inaugural members of the Global Compact LEAD, which outlines actions through which businesses around the world can achieve greater sustainability.’

http://www.accenture.com/microsites/corporate-citizenship-report-2012/corporate-governance/Pages/zero-tolerance.aspx

‘We are also involved in a number of industry initiatives designed to combat corruption, including the World Economic Forum's Partnering Against Corruption Initiative, which brings together companies through a universal commitment to having a zero-tolerance policy toward bribery and to developing, implementing and maintaining broad-based anticorruption programs.’



http://www.accenture.com/us-en/company/citizenship/Pages/ungc-indices.aspx




http://www.weforum.org/issues/partnering-against-corruption-initiative

‘Professional Services: Accenture, Deloitte, Ernst & Young, KPMG International, PricewaterhouseCoopers International’

http://www.weforum.org/issues/partnering-against-corruption-initiative


A6:

Has the company appointed a Board committee or individual Board member with overall corporate responsibility for its ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company’s Audit Committee has overall corporate responsibility for its entire ethics and compliance agenda. This responsibility includes reviewing and investigating any matters pertaining to the integrity of management. The Global Management Committee has management oversight of the anti-corruption programme specifically.

References:

Public:

Audit Committee Charter, 2013, p.1:

http://www.accenture.com/SiteCollectionDocuments/About-Accenture/Accenture-audit-committee-charter.pdf

‘The Company’s compliance with legal and regulatory requirements’

(p.6): Duties and responsibilities include:

‘(i) Review, with the Company’s counsel, any legal matter that could have a significant impact on the Company’s financial statements or operations;

(ii) Oversee the Company’s compliance program and adherence to its Code of Business Ethics. This shall include a review and investigation of any matters pertaining to the integrity of management, including conflicts of interest;

(iii) Establish procedures for: (i) the receipt, retention and treatment of complaints received by the Company regarding accounting, internal accounting controls, or auditing matters; and (ii) the confidential anonymous submission by employees of the Company of concerns regarding questionable accounting or auditing matters; and

(iv) Ensure that the Company maintains (either as an internal function or as an outsourced service) an internal audit function.’





‘Our director of Anticorruption Law reports to an associate general counsel, and ultimate program oversight resides with our general counsel and compliance officer. Our Global Management Committee provides management oversight to the anticorruption program and the Audit Committee of our board of directors oversees the Ethics & Compliance program as a whole.’


‘Our senior management is responsible and accountable for implementing all of our corporate policies. Our GMC provides management oversight to our anticorruption program, and the Audit Committee of our Board of Directors oversees our Ethics & Compliance program. This structure allows the Ethics & Compliance program a degree of independence in order to prevent any conflicts of interest.’

GMC = Global Management Committee


‘Our Board of Directors directly and through the Audit Committee oversees our Ethics & Compliance program. The Board of Directors receives at least an annual update on the program and the Audit Committee receives quarterly updates’

UN Global Compact: Communication on Progress, 2011: 15

‘Our senior management is responsible and accountable for implementing our policy. Our director of Anticorruption Law reports to an associate general counsel, and ultimate program oversight resides with our general counsel and compliance officer. Our Global Management Committee provides management oversight to the anticorruption program, and the Audit Committee of our board of directors oversees the Ethics and Compliance program as a whole. Additionally, the compliance officer reports to the Audit Committee on program activities and plans at least annually.’






A7:

Has the company appointed a person at a senior level within the company to have responsibility for implementing the company’s ethics and anti-corruption agenda, and who has a direct reporting line to the Board?

Score:

2

Comments:

Based on public information, there is evidence that the company has appointed General Counsel, Secretary and Chief Compliance Officer, Julie Spellman Sweet, with responsibility for implementing the company’s ethics and compliance programme. The Chief Compliance Officer reports to the Audit Committee.

References:

Public:


‘This commitment is further manifested in Accenture’s Ethics & Compliance program, which is authorized by Accenture’s Board and managed by our General Counsel, Secretary and Chief Compliance Officer.’

http://www.accenture.com/us-en/company/people/Pages/julie-spellman-sweet.aspx

Julie Spellman Sweet: General Counsel, Secretary & Chief Compliance Officer

‘As chief compliance officer, Ms. Sweet is responsible for managing legal and regulatory compliance programs that enable Accenture to operate around the globe while adhering to the highest ethical standards.’


‘Our director of Anticorruption Law reports to an associate general counsel, and ultimate program oversight resides with our general counsel and compliance officer. Our Global Management Committee provides management oversight to the anticorruption program and the Audit Committee of our board of directors oversees the Ethics & Compliance program as a whole.’


http://www.accenture.com/us-en/company/people/Pages/julie-spellman-sweet.aspx




UN Global Compact: Communication on Progress, 2011: 15

‘Our senior management is responsible and accountable for implementing our policy. Our director of Anticorruption Law reports to an associate general counsel, and ultimate program oversight resides with our general counsel and compliance officer. Our Global Management Committee provides management oversight to the anticorruption program, and the Audit Committee of our board of directors oversees the Ethics and Compliance program as a whole. Additionally, the compliance officer reports to the Audit Committee on program activities and plans at least annually.’


A8:

Is there regular Board level monitoring and review of the performance of the company’s ethics and anti-corruption agenda?

Score:

2

Comments:

Based on public information, there is evidence that the Board of Directors receives an annual update on the company’s ethics and compliance agenda, and the Audit Committee receives quarterly updates. This suggests that a major review of the performance of the company’s ethics and anti-corruption agenda occurs at these intervals.

References:

Public:


‘Oversee the Company’s compliance program and adherence to its Code of Business Ethics. This shall include a review and investigation of any matters pertaining to the integrity of management, including conflicts of interest;’

‘Ensure that the Company maintains (either as an internal function or as an outsourced service) an internal audit function.’

‘Report regularly to the Board:

a. with respect to any issues that arise regarding the quality or integrity of the Company’s financial statements, the Company’s compliance with legal and regulatory requirements, the performance and independence of the Company’s independent auditors or the performance of the internal audit function;’


‘On January 29, 2014, Accenture's Board of Directors adopted amendments to the Code of Business Ethics. The purpose of the amendments was to update the Code of Business Ethics with respect to business and regulatory developments as well as to provide additional guidance and greater detail about various matters, including the use of social media, compliance with laws, and political contributions.’

http://www.accenture.com/microsites/corporate-citizenship-report-2012/corporate-




governance/Pages/zero-tolerance.aspx

‘To ensure that our anticorruption compliance program and our business practices are up to date, we review them annually, both at the geography level and, for high-risk countries, at the global level.’

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-governance/Pages/goals-and-progress.aspx

‘Conduct regular risk assessments of our global compliance program and share enhancements made as a result of those assessments

Progress: In fiscal 2012 and 2013, we significantly enhanced our Ethics & Compliance program in several areas, including training and communications

New Goal: In fiscal 2014, we will update our Code of Business Ethics to reflect business and regulatory developments and to provide additional guidance and detail about areas such as the use of social media and political contributions’

‘We strive to improve our Ethics & Compliance program on an ongoing basis. In fiscal 2012, we developed a new approach to help ensure training topics are timely and relevant to our employees. We also refined the process for scheduling regular risk assessments to improve our ability to identify and address emerging risks, and we enhanced communications to help ensure our employees have information on key ethics and compliance topics.

Additionally, we made our training more scenario-based to reflect potential situations we might face and to improve employee comprehension and retention. Finally, we simplified key policies, including those related to personal conduct and social media, as well as our anticorruption compliance program, and made them more accessible to our people.’


‘To help ensure training topics are relevant to our employees and timely to our business, in fiscal 2012, we developed a new approach to determine employee training topics. Now, our Ethics group consults annually with senior leaders to evaluate potential topics for the full year’s Ethics & Compliance training curriculum. As part of this approach, risk assessments evaluate current business priorities, recent internal and external changes (for example, new policies or laws), current trends, time since last training and emerging risks that are most relevant to Accenture.

In fiscal 2013, we continued to develop live and online methods that enhance engagement with our training and encourage employees to apply key learnings. To boost information retention, we employ a comprehensive communications approach that includes a training session on each ethics and compliance topic, including our COBE. We then disseminate refresher information through a variety of channels, including our internal employee portal; e-mails from leadership to launch new training; newsletters to discuss compliance topics and reinforce training; and local communications from business leaders on relevant ethics and compliance topics.

In fiscal 2012 and 2013, we added a new course on third-party intellectual property and refreshed our information security training. We also updated our anticorruption training to







address program enhancements, and we revamped existing training topics with scenarios relevant to situations that employees might face.

Our year-long mandatory training program tracks results through ethical perception surveys, use of employee tools such as policies and the COBE site, and pre- and post-tests that demonstrate increased knowledge. Completion rates are in the high 90th percentile, which is an indicator for us of success; 100 percent is unattainable due to leaves of absence and ongoing hiring of employees. We factor Ethics & Compliance training completion into employees’ annual performance ratings and/or resulting performance-based compensation. In fact, this training is so essential to our success that, as local law permits, failure to complete required training affects employee performance ratings.


‘We conduct periodic risk assessments in each of our geographies to measure the strength of our anticorruption policies against potential and emerging risks such as anticorruption laws, competition law, data privacy protection, trade compliance and workplace conduct. We place a particular focus on the higher-risk countries where we do business.

In fiscal 2012, after a thorough review of the key elements of our program (that is, leadership; risk assessment; standards and control; training and communication; and monitoring, auditing and response), we began enhancing our global anticorruption efforts. Co-sponsored by our General Counsel, Secretary & Chief Compliance Officer and members of our Global Management Committee, these enhancements are part of our commitment to continue evolving and improving on our programs in the fight against bribery and corruption globally.

This is part of what makes Accenture unique. Because our breadth of services and geographies is so broad, we are involved in both regulated and unregulated industries and in industrialized and growth markets, which requires our Ethics & Compliance programs to keep up with a multitude of changing issues. Our challenge is to stay abreast of these changes and train our employees to understand how those changes affect their everyday work.’


‘Our Board of Directors directly and through the Audit Committee oversees our Ethics & Compliance program. The Board of Directors receives at least an annual update on the program and the Audit Committee receives quarterly updates’




A8(a):

Is there a formal, clear, written plan in place on which the review of the ethics and anti-corruption agenda by the Board or senior management is based, and evidence of improvement plans being implemented when issues are identified?

Score:

1

Comments:

Based on public information, there is some evidence that there is an underlying structure, which guides the review of the ethics and anti-corruption agenda. The Board of Directors receives an annual update on the company’s ethics and compliance agenda and the Audit Committee receives quarterly updates, but the company does not specify what these reviews are based upon. In contrast, there is evidence that improvement plans are implemented when issues are identified. In 2012 the company implemented enhancements to their anti-corruption programme after completing a review of each of its main elements, such as leadership and education. Also, the 2014 Corporate Citizenship Report states that the company has a goal to upgrade the Code of Ethics. However, there is limited explicit evidence of a formal, clear, written plan that guides the Board level review of the ethics and anti-corruption agenda. The company therefore scores 1.

References:

Public:


‘Oversee the Company’s compliance program and adherence to its Code of Business Ethics. This shall include a review and investigation of any matters pertaining to the integrity of management, including conflicts of interest;’

‘Ensure that the Company maintains (either as an internal function or as an outsourced service) an internal audit function.’

‘Report regularly to the Board:

a. with respect to any issues that arise regarding the quality or integrity of the Company’s financial statements, the Company’s compliance with legal and regulatory requirements, the performance and independence of the Company’s independent auditors or the performance of the internal audit function;’



‘On January 29, 2014, Accenture's Board of Directors adopted amendments to the Code of Business Ethics. The purpose of the amendments was to update the Code of Business Ethics with respect to business and regulatory developments as well as to provide additional guidance and greater detail about various matters, including the use of social media, compliance with laws, and political contributions.’


‘Conduct regular risk assessments of our global compliance program and share enhancements made as a result of those assessments

Progress: In fiscal 2012 and 2013, we significantly enhanced our Ethics & Compliance program in several areas, including training and communications

New Goal: In fiscal 2014, we will update our Code of Business Ethics to reflect business and regulatory developments and to provide additional guidance and detail about areas such as the use of social media and political contributions’

‘We strive to improve our Ethics & Compliance program on an ongoing basis. In fiscal 2012, we developed a new approach to help ensure training topics are timely and relevant to our employees. We also refined the process for scheduling regular risk assessments to improve our ability to identify and address emerging risks, and we enhanced communications to help ensure our employees have information on key ethics and compliance topics.

Additionally, we made our training more scenario-based to reflect potential situations we might face and to improve employee comprehension and retention. Finally, we simplified key policies, including those related to personal conduct and social media, as well as our anticorruption compliance program, and made them more accessible to our people.’


‘To help ensure training topics are relevant to our employees and timely to our business, in fiscal 2012, we developed a new approach to determine employee training topics. Now, our Ethics group consults annually with senior leaders to evaluate potential topics for the full year’s Ethics & Compliance training curriculum. As part of this approach, risk assessments evaluate current business priorities, recent internal and external changes (for example, new policies or laws), current trends, time since last training and emerging risks that are most relevant to Accenture.








In fiscal 2012 and 2013, we added a new course on third-party intellectual property and refreshed our information security training. We also updated our anticorruption training to address program enhancements, and we revamped existing training topics with scenarios relevant to situations that employees might face.



‘We conduct periodic risk assessments in each of our geographies to measure the strength of our anticorruption policies against potential and emerging risks such as anticorruption laws, competition law, data privacy protection, trade compliance and workplace conduct. We place a particular focus on the higher-risk countries where we do business.



UN Global Compact : Communication on Progress, 2013, p.19:

‘Our Board of Directors directly and through the Audit Committee oversees our Ethics & Compliance program. The Board of Directors receives at least an annual update on the program and the Audit Committee receives quarterly updates. Our Chairman & CEO plays a key role in establishing tone from the top. He visibly and frequently communicates on these matters. Two primary messages are: (1) we have zero tolerance for violations of law and for retaliation against employees reporting issues and (2) a strong ethics and compliance program is an essential part of being a high-performance company and in reaching our goals as a company.’

‘We assess the risk of anticorruption at least annually at the geography level, with particular




attention focused on the higher-risk countries in which we do business. In 2012, we began implementing enhancements to our global anticorruption program after completing a review of each of the main elements of our program (leadership, risk assessments, standards and controls, education and awareness, and response, audit and monitoring). These enhancements were co-sponsored by our General Counsel, Secretary & Chief Compliance Officer and members of our Global Management Committee and are part of our commitment to continuous improvement in the fight against bribery and corruption globally.’


A9:

Does the company have a formal process for review and where appropriate update its policies and practices in response to actual or alleged instances of corruption?

Score:

2

Comments:

Based on public information, there is evidence of a formal process for reviewing and updating the company’s policies and practices, in response to actual or alleged instances of corruption. The Corporate Investigations team conducts reviews of any ethics and compliance-related concerns. It may recommend updates such as additional training and awareness, or improvements to internal processes and controls. The company has an escalation protocol for significant ethics and compliance-related matters.

References:

Public:

UNGC: Communication on Progress (March 2013), p.20:

‘Once a concern is raised, our Corporate Investigations team, part of our Legal group, scopes and conducts an independent and objective review, following a consistent and standard process, and recommends and implements appropriate remedial measures.

Resolution may include additional training and awareness, process improvements and disciplinary measures as appropriate, up to and including termination of employment. Our standard escalation protocol for COBE concerns involves, as appropriate, senior business leadership, senior human resources leadership, senior legal leadership and regular reporting to Internal Audit, our external auditors and our Audit Committee.’

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-governance/Pages/reporting-and-response.aspx

‘Monitoring and enforcement are integral to our corporate governance and Ethics & Compliance programs. We actively encourage employees to raise all ethics and compliance-related concerns, and we make multiple channels available for them to do so—by name or anonymously. These channels include direct supervisors and career counselors, a 24/7 Business Ethics Line and website, and Accenture Leadership—from our business, Legal and Human Resources. In all instances, we have zero tolerance for retaliation against those who




raise concerns, which helps ensure our employees are comfortable speaking up.

We take every concern that is raised seriously, and we respond expeditiously. Our Corporate Investigations team, part of our Legal group, undertakes an independent, objective review and recommends appropriate remedial measures, if any. Resolution may include additional training and awareness, improvements in internal processes and controls and/or disciplinary measures. While we often handle investigations in house, we will, at times, involve third parties (such as law enforcement), where appropriate. Our standard escalation protocol for significant Code of Business Ethics matters involves members of Accenture Leadership, Legal and Human Resources, as appropriate, and calls for regular reporting to Internal Audit, our external auditors and our Audit Committee.’


A9(a):

Does the company have a formal anti-corruption risk assessment procedure implemented enterprise-wide?

Score:

2

Comments:

Based on public information, there is evidence that the company has an enterprise-wide anti-corruption risk assessment procedure. The company carries out regular and periodic risk assessments of its Ethics and Compliance programme. For example, a geographical anti-corruption risk assessment is conducted at least annually and focuses upon high-risk countries. TI notes that the company’s 2010 UNGC Communication on Progress report describes in greater detail the enterprise-wide anti-corruption risk assessment procedure and there is evience in later documents of improvement and mitigation plans.

References:

Public:

Code of Business Ethics (2014), p. 11:

‘• We are holistic in our assessment of risk. We want to anticipate, assess and manage risk in a thoughtful and transparent way. While we seek to align all elements of the deal, we recognize that our complex business environment can prevent this alignment. We therefore create thoughtful and robust risk management plans that clearly identify the risks with the corresponding mitigating actions and ownership by named individuals for each action. We also establish solution contingency based on the risks and the confidence in our mitigation plan.’


Company website, Assessing Risk Globally:

‘Assessing risk globally

We conduct periodic risk assessments in each of our geographies to measure the strength of our anticorruption policies against potential and emerging risks such as anticorruption laws, competition law, data privacy protection, trade compliance and workplace conduct. We place a particular focus on the higher-risk countries where we do business.







Audit Committee Charter, 2013, p.5-6:

‘Risk Management

(i) Discuss with management and the independent auditors the Company’s guidelines and policies with respect to risk assessment and risk management. The Committee should discuss the Company’s major financial risk exposures and the steps management has taken to monitor and control such exposures. Such reviews shall include the following:

a. A quarterly review with the Chief Operating Officer (or such other executive or executives with primary responsibility for risk oversight) of the Company’s enterprise risks and risk management;

b. An annual review (or more frequently as appropriate) with such person or persons of the process by which the Company manages its enterprise risks; and

c. An annual review with the chair of each of the Compensation Committee and the Finance Committee of the risk assessment process undertaken by those committees with respect to the risks overseen by those committees’



Accenture has adopted a framework designed to achieve these objectives, which includes (i) visible support of our senior leadership, (ii) regular and periodic risk assessments, (iii) written standards and controls, (iv) ongoing training and communications, and (v) auditing,





monitoring, and response procedures.’


‘As a global company, we acknowledge that we have a higher risk in doing business in certain industries and locations. Therefore, we focus on having a robust compliance program to enable corporate-wide compliance with both the spirit and letter of all antibribery and anticorruption laws everywhere we conduct business. Our internal compliance, training and awareness programs are designed to prevent, detect and remedy policy and Code violations worldwide.’

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-governance/Pages/strategy-framework-and-guidelines.aspx

‘Our formal Ethics & Compliance program comprises four areas:

Global compliance programs that address our highest compliance risk areas, such as a global anticorruption compliance

A Code of Business Ethics that reflects our core values—Client Value Creation, One Global Network, Respect for the Individual, Best People, Integrity and Stewardship

Compliance plans for our joint ventures and affiliates

An annual, five-element assessment of other global risks, such as social media, on which we need to focus’

‘To help ensure that all of Accenture’s compliance programs are strategic, we evaluate existing compliance programs and implement new ones around a five-element framework that involves: leadership; risk assessment; standards and control; training and communication; and monitoring, auditing and response.’


‘We assess the risk of anticorruption at least annually at the geography level, with particular attention focused on the higher-risk countries in which we do business. In 2012, we began implementing enhancements to our global anticorruption program after completing a review of each of the main elements of our program (leadership, risk assessments, standards and controls, education and awareness, and response, audit and monitoring). These enhancements were co-sponsored by our General Counsel, Secretary & Chief Compliance Officer and members of our Global Management Committee and are part of our commitment to continuous improvement in the fight against bribery and corruption globally.’

UN Global Compact : Communication on Progress, 2011: 15

‘We perform periodic qualitative and quantitative risk assessments for corruption and share the results with our most senior leadership, the Audit Committee of the board of directors and the full board. We are currently conducting an assessment of our anticorruption program with outside counsel and key internal stakeholders.’






http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-UNGC-Communication-on-Progress-(March%202011).pdf

UN Global Compact: Communication on Progress Report – Supplemental Report on Principle 10 (2010), p.3:

‘We perform qualitative and quantitative risk assessments for corruption, as well other significant compliance risks on a periodic basis. The results of those assessments are shared with our most senior leadership, the Audit Committee of the board of directors as well as the full board. Detailed results are reviewed with key stakeholders who plan and implement risk mitigation actions as appropriate. In addition, we utilize a network of local “ethics and compliance leads” – executives from our business operating groups—to perform local country ethics and compliance risk reviews in certain countries. Also, our Internal Audit group performs regular audits of our country operations for compliance with our anticorruption policies and procedures. Finally, in 2009, we hired a third-party consultant to conduct a risk assessment of various areas of our operations, including anticorruption compliance. We will continue to conduct risk assessments of potential areas of corruption.’

(p.9): ‘As a US issuer, we are required to have a strong internal audit function to ensure that we maintain accurate books and records and have adequate internal controls. On a periodic basis, our Ethics & Compliance group works with Internal Audit to collaborate on risk prioritization, to review our scope of operations and to develop a risk-based internal audit plan for conducting geography audits of our business development agent procedures. The geography audits are conducted during a two-to-five-year cycle. In addition, on an annual basis, Internal Audit conducts a global audit, which includes a review of our anticorruption compliance procedures to supplement the geography audits. In 2010, we intend to update our geographic internal audit plan to expand the review of additional aspects of our anticorruption compliance program.’

http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture_UNGC_Communication_on_Progress_Report.pdf






A10:

Does the company have a formal anti-corruption risk assessment procedure for assessing proposed business decisions, with clear requirements on the circumstances under which such a procedure should be applied?

Score:

0

Comments:

Based on public information, there is no readly available evidence that the company has a formal anti-corruption risk assessment procedure for assessing proposed business decisions. Despite the company implementing global risk assessments at least annually, with particular focus on high-risk countries, there is no evidence this process is carried out for proposed business decisions. TI notes that the company’s 2010 UNGC Communication on Progress report, states that it conducts due diligence in M&As. However, more recent reports or company policies do not confirm this. Therefore, the company is unable to score on this question.

References:

Public:


‘We assess the risk of anticorruption at least annually at the geography level, with particular attention focused on the higher-risk countries in which we do business. In 2012, we began implementing enhancements to our global anticorruption program after completing a review of each of the main elements of our program (leadership, risk assessments, standards and controls, education and awareness, and response, audit and monitoring). These enhancements were co-sponsored by our General Counsel, Secretary & Chief Compliance Officer and members of our Global Management Committee and are part of our commitment to continuous improvement in the fight against bribery and corruption globally.’


‘As a global company, we acknowledge that we have a higher risk in doing business in certain industries and locations. Therefore, we focus on having a robust compliance program to enable corporate-wide compliance with both the spirit and letter of all




antibribery and anticorruption laws everywhere we conduct business. Our internal compliance, training and awareness programs are designed to prevent, detect and remedy policy and Code violations worldwide.’


‘We also require risk-based anticorruption due diligence in mergers and acquisitions and incorporation of anticorruption terms and conditions in resultant agreements. Indeed, in 2009, we provided live anticorruption compliance training to a government-owned joint venture partner in China and negotiated terms in the joint venture agreement requiring the venture to implement a compliance program based on our core values.’


A11:

Does the company conduct due diligence that minimises corruption risk when selecting or reappointing its agents?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company conducts due diligence when selecting or reappointing agents. The company states that all higher-risk third parties are subject to due diligence, but TI is looking for evidence that all agents are subject to due diligence. The 2011 version of the Code of Business Ethics suggests that all agents must pass due diligence. However, this information cannot be found in the 2014 version of the Code. Similarly, the company’s 2010 UNGC Communication on Progress report states that it conducts due diligence before selecting agents. However, more recent reports or company policies do not confirm this. The company is therefore unable to score on this question.

References:

Public:


http://www.accenture.com/SiteCollectionDocuments/PDF/219000_CoBE_Brochure_v5.2_English.pdf

‘Only ethical, qualified agents help sell our services. We hire agents to help open doors and sell Accenture’s services only after they have passed our due diligence and approval procedures.’

UN Global Compact : Communication on Progress, 2013: 21

‘• All higher-risk third parties with which we wish to do business are subject to due diligence and an approval process involving appropriate Accenture Leadership to help ensure that they are reputable and will act in accordance with our anticorruption compliance program.’


‘Using a risk-based approach, we have developed mechanisms to address anticorruption




risks in our dealings with business partners. We consider business development agents to represent an important risk area in our operations. Accordingly, we maintain detailed policies and procedures requiring due diligence concerning agents; processing through a multi-stakeholder approval process prior to engaging the agent; inclusion of rigorous anticorruption terms and conditions in business development agent contracts, including audit rights of agent books and records; annual certification to compliance with such terms and conditions; training to agents; mandatory business monitoring of agent activities; and centralized tracking of agent retention and renewal activities via a Web-based portal.’


A12:

Does the company have contractual rights and processes for the behaviour, monitoring, control, and audit of agents with respect to countering corruption?

Score:

0

Comments:

Based on public information, there is evidence that agents must comply with the company’s Code of Business Ethics. However, there is no evidence that the company has contractual rights for the monitoring and audit of agents with respect to countering corruption, nor does it have contractual rights to deal with the occurrence of any violations. TI notes that the company’s 2010 UNGC Communication on Progress report states that it has the right to monitor and audit agents. However, more recent reports or company policies do not confirm this. Therefore, the company is unable to score on this question.

References:

Public:



Accenture has adopted a framework designed to achieve these objectives, which includes (i) visible support of our senior leadership, (ii) regular and periodic risk assessments, (iii) written standards and controls, (iv) ongoing training and communications, and (v) auditing, monitoring, and response procedures.

The program extends to cover not just Accenture’s employees, but also those who work on Accenture’s behalf as contractors and other third parties, as well as Accenture Federal Services, which has adopted standards that supplement Accenture’s standards.’

Code of Business Conduct, 2014, p.4:

‘The Code of Business Ethics applies to all Accenture people—Accenture’s directors, officers and employees in every country, workforce and entity that is consolidated in Accenture’s financial statements or otherwise controlled by Accenture. In addition, while



some Accenture companies have their own codes of conduct that may supplement this document, this Code of Business Ethics also applies to employees of those entities unless the entity’s code of conduct is approved for use in lieu of Accenture’s Code of Business Ethics by Accenture’s General Counsel. With respect to entities in which Accenture has an interest but does not have control, we encourage them to adopt and follow the Code of Business Ethics as appropriate. In addition, third parties, such as consultants, agents and independent contractors, are required to comply with the Code of Business Ethics when acting on Accenture’s behalf. In certain Accenture functional areas, such as procurement, finance or on particular client engagements, more stringent requirements may apply.’

UN Global Compact: Communication in Progress, 2013, p.20:

‘• Our COBE expressly applies to third parties, such as consultants, agents and independent contractors when acting on Accenture’s behalf.

• We expect all of our suppliers to comply with our Supplier Standards of Conduct, which are available in 14 languages. In turn, Accenture expects its suppliers to apply these standards to their suppliers.’

(p.19): ‘Our Code of Business Ethics (COBE) and related policies require all employees, business partners and suppliers to abide by the spirit and letter of all antibribery and anticorruption laws everywhere we do business.’


‘Using a risk-based approach, we have developed mechanisms to address anticorruption risks in our dealings with business partners. We consider business development agents to represent an important risk area in our operations. Accordingly, we maintain detailed policies and procedures requiring due diligence concerning agents; processing through a multi-stakeholder approval process prior to engaging the agent; inclusion of rigorous anticorruption terms and conditions in business development agent contracts, including audit rights of agent books and records; annual certification to compliance with such terms and conditions; training to agents; mandatory business monitoring of agent activities; and centralized tracking of agent retention and renewal activities via a Web-based portal.’


A13:

Does the company make clear to contractors, sub-contractors, and suppliers, through policy and contractual terms, its stance on bribery and corruption and the consequences of breaches to this stance?

Score:

2

Comments:

Based on public information, there is evidence that the company makes clear to contractors, sub-contractors, and suppliers, through its Code of Business Ethics and Supplier Standards of Conduct, the company’s stance on bribery and corruption. The company has contractual rights to apply sanctions, including contract termination, if a supplier violates the Supplier Standards of Conductor or applicable laws and regulations.

References:

Public:


‘Accenture’s Ethics & Compliance program […]extends to cover not just Accenture’s employees, but also those who work on Accenture’s behalf as contractors and other third parties, as well as Accenture Federal Services, which has adopted standards that supplement Accenture’s standards.’

Supplier Standards of Conduct, 2014

http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-Supplier-Standards-of-Conduct_English-Feb-2014.pdf

Available in 14 languages

(p.2): ‘As we continually strive to deliver high performance for our clients, our company and our shareholders, Accenture is committed to upholding the highest ethical and professional standards consistent with our core values, the Accenture Code of Business Ethics and the Ten Principles of the United Nations Global Compact, of which Accenture is a signatory.

The relationship between Accenture and its suppliers is an important component to achieving high performance in our business. Our Accenture Supplier Standards of Conduct, which supplement our Code of Business Ethics, set forth the standards and practices that





Accenture suppliers are required to uphold.

Accenture is committed to helping its suppliers comply with these standards. In turn, Accenture expects its suppliers to apply these standards to their suppliers.

(p.3): ‘Our Supplier Standards of Conduct is built on the framework of Accenture’s core values: Stewardship, Best People, Client Value Creation, One Global Network, Respect for the Individual and Integrity. Our core values shape the culture and define the character of our company. They guide how we behave and make decisions. Each core value is supported by action statements and specific behaviors that we expect of our suppliers.’

(pp.5-6): ‘6 Integrity

Accenture suppliers understand and comply with all applicable laws. Suppliers inspire trust by taking responsibility, acting ethically and encouraging honest and open debate.

6.1 Do not offer inappropriate gifts to Accenture employees or clients

Accenture suppliers do not provide gifts to any Accenture employee or client to obtain or retain business or to influence a decision. In limited circumstances suppliers may provide nominal gifts that may not exceed US$25 or lower limits established by local Accenture policy.

6.2 Comply with all antibribery laws including the U.S. Foreign Corrupt Practices Act

Accenture is committed to conducting its business free from extortion, bribery and all unlawful, unethical or fraudulent activity. Accenture suppliers comply with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act.

In connection with doing business with Accenture, suppliers do not offer, promise, authorize, give, demand or accept any gift, loan, fee, reward or other advantage to or from any person as an inducement; to do something which is dishonest, illegal or a breach of trust; to obtain, retain or direct business; or to secure any other improper advantage. Under these standards, improper payments include offers, promises, authorizations or payments of anything of value to expedite routine government actions.

Suppliers shall implement adequate procedures for supplier employees to comply with applicable anticorruption laws and these standards.’

(p.6): ‘Violation of Our Supplier Standards of Conduct

Failure to comply with these standards or with applicable laws and regulations may result in termination as an Accenture supplier and referral of the matter to local authorities.

Accenture suppliers may report suspected violations of these standards or specific concerns regarding Accenture’s financial affairs, accounting practices, auditing matters, corruption or fraud—and in serious cases where the vital interest of the company or the moral or physical integrity of our people are at stake—to the Accenture Business Ethics Line globally at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available 24 hours a day, seven days a week (you can reverse the charges). Use the Business Ethics Line only to make a good faith claim. Accenture takes all allegations seriously.

Note: Additional requirements may apply for suppliers supporting Accenture’s business with


U.S. government clients, as set forth in Accenture’s Standards of Federal Business Ethics and Conduct at: Accenture Code of Business Ethics ‘


‘Our Code of Business Ethics (COBE) and related policies require all employees, business partners and suppliers to abide by the spirit and letter of all antibribery and anticorruption laws everywhere we do business.

(p.21): ‘• Our COBE expressly applies to third parties, such as consultants, agents and independent contractors when acting on Accenture’s behalf.

• We expect all of our suppliers to comply with our Supplier Standards of Conduct, which are available in 14 languages. In turn, Accenture expects its suppliers to apply these standards to their suppliers.’

‘• All higher-risk third parties with which we wish to do business are subject to due diligence and an approval process involving appropriate Accenture Leadership to help ensure that they are reputable and will act in accordance with our anticorruption compliance program.’

(p.20): ‘100%: Percentage of suppliers who access our systems required to complete Accenture training’

UN Global Compact: Communication on Progress, 2011, 16:

‘In fiscal 2010, we introduced new ethics training courses, information security and data privacy compliance training for all suppliers requiring an Accenture e-mail address and ID. Suppliers must complete the training in 21 days; failure to do so means that they will lose their Accenture e-mail and ID. To date, more than 80 percent of all in-scope suppliers have completed the training.’

‘We introduced checklists to assess our suppliers’ compliance with applicable data privacy laws, as well as their compatibility with Accenture’s approach to data privacy and client data protection.’

‘We enhanced supplier background screening for self-employed/independent contractors, and it is now needed to receive an Accenture e-mail address and ID.’

‘We have increased our due diligence in supply chain financial screening. Our Corporate Treasury team now performs a deep financial analysis of all suppliers responding to critical global technology RFPs and North American contractor RFPs. We then screen selected suppliers on an ongoing basis throughout our agreement with them, and they must provide us with current financial reports as often as quarterly. Existing critical suppliers go through the same screening on a regular basis, and we use the results as performance review discussion points and input for the next sourcing process.’


A13(a):

Does the company explicitly address the corruption risks associated with offset contracting?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

Public:

NA


A13(b):

Does the company conduct due diligence that minimises corruption risk when selecting its offset partners and offset brokers?

Score:

NA

Comments:

The company has informed TI that it does not engage in offset contracting.

References:

Public:

NA


A15:

Does the company have an anti-corruption policy that prohibits corruption in its various forms?

Score:

2

Comments:

Based on public information, there is evidence that the company’s anti-corruption policy prohibits corruption in its various forms. The Code of Business Ethics prohibits the giving or receiving of bribes, as well as covering conflicts of interest and gift and hospitality exchange.

References:

Public:


‘7. We refuse to make or take bribes or to make questionable payments.






‘Q&A for Integrity Action Statement #7

What are some warning signs that suggest we use extra caution?

• An Accenture business intermediary asks for an unusually large or contingent fee.


• An Accenture business intermediary’s reputation is questionable.

• We are asked to make payment to another person, in another country, to a numbered bank account or to pay in cash.

• We are doing business in a country that has a reputation for corruption.

• An Accenture agent has a family or business relationship with a public official.

• Our client asks us to make a political or charitable contribution or to use a particular subcontractor.

• An Accenture business intermediary asks for an increase in the agreed fees to close the deal.’

(p.8): ‘5. We avoid actual and perceived conflicts of interest and ensure that our personal and financial relationships and activities do not compromise Accenture’s objectivity or reputation.

6. We do not accept or give inappropriate gifts or entertainment.

7. We refuse to make or take bribes or to make questionable payments.’

United Nations Global Compact: Communication on Progress, 2013, p.18:

http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-2013-UN-Global-Compact-Communication-on-Progress.pdf

‘Accenture is committed to maintaining the highest ethical standards and to complying with all anticorruption laws where we operate around the world. To this end and as reflected in our internal policies, we have zero tolerance for bribery or any other activity that violates the anticorruption laws in any place we conduct business.’




A16:

Is the anti-corruption policy explicitly one of zero tolerance?

Score:

2

Comments:

Based on public information, there is evidence that the company has zero tolerance for corruption.

References:

Public:


‘As you know, not every issue that comes up has a clear path to resolution. In fact, some situations have multiple ways they can be resolved, each with its own benefits and consequences for you and Accenture, so we expect you to reach out for help. When it is clear how to apply the law or our policy, we have zero tolerance for violations. In more difficult situations that involve hard judgments between competing values, we expect you to use good judgment and to involve others to help make good decisions’

http://newsroom.accenture.com/article_display.cfm?article_id=6028

‘In recognition of Accenture’s strict adherence to ethics and compliance, which includes zero tolerance for corruption in all its forms, the company has been included on Ethisphere’s “World’s Most Ethical Companies” list for seven consecutive years.’


‘We have a publicly stated formal policy of zero tolerance for corruption or serious violations of our Code of Business Ethics. This policy supports our commitment to work against corruption in all its forms, including bribery and extortion.’


‘The 58 action statements align with our core values and describe expected behaviors, such as zero tolerance for corruption in all its forms, including extortion, bribery or any activity

http://newsroom.accenture.com/article_display.cfm?article_id=6028






that violates laws and regulations in places where we conduct business. We review and update these action statements regularly to keep them current with our changing business priorities.


‘To this end and as reflected in our internal policies, we have zero tolerance for bribery or any other activity that violates the anticorruption laws in any place we conduct business.’

(p.21): ‘Going forward, we will continue to maintain zero tolerance for corruption and to work against it in all its forms.’


A17:

Is the company's anti-corruption policy easily accessible to Board members, employees, contracted staff and any other organisations acting with or on behalf of the company?

Score:

2

Comments:

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily accessible to Board members, employees and third parties. In particular, the Code of Business Ethics is available in 19 languages on the company website.

References:

Public:

Supplier Standards of Conduct, 2014

‘Where to Go for Additional Information and Help:

Accenture Code of Business Ethics

Accenture Core Values’

Code of Business Ethics available in 19 languages.


‘Our intent is for employees to reference our COBE to better understand our ethical standards and incorporate this understanding into their daily decision making. To support this, our internal employee portal features an interactive, fully searchable version of our COBE in 19 languages. The interactive website also provides access to a vast set of resources, including scenarios depicting ethical dilemmas, policy information, FAQs for each action statement, training, key terms, subject matter experts, collaboration tools and more.’


‘The Code of Business Ethics applies to all Accenture people—Accenture’s directors, officers and employees in every country, workforce and entity that is consolidated in Accenture’s financial statements or otherwise controlled by Accenture. In addition, while some Accenture companies have their own codes of conduct that may supplement this




document, this Code of Business Ethics also applies to employees of those entities unless the entity’s code of conduct is approved for use in lieu of Accenture’s Code of Business Ethics by Accenture’s General Counsel. With respect to entities in which Accenture has an interest but does not have control, we encourage them to adopt and follow the Code of Business Ethics as appropriate. In addition, third parties, such as consultants, agents and independent contractors, are required to comply with the Code of Business Ethics when acting on Accenture’s behalf. In certain Accenture functional areas, such as procurement, finance or on particular client engagements, more stringent requirements may apply.’

UNGC Communications on Progress Report 2013, p.19:

‘The COBE is currently available in 16 languages and is accessible online.’


A17(a):

Is the company’s anti-corruption policy easily understandable and clear to Board members, employees and third parties?

Score:

2

Comments:

Based on public information, there is evidence that the company’s ethics and anti-corruption policies are easily understandable to Board members, employees and third parties. In particular, the Code of Business Ethics is written in comprehensible language, is well structured and contains several questions and answers.

References:

Public:




‘7. We refuse to make or take bribes or to make questionable payments.










What are some warning signs that suggest we use extra caution?

• An Accenture business intermediary asks for an unusually large or contingent fee.

• An Accenture business intermediary’s reputation is questionable.

• We are asked to make payment to another person, in another country, to a numbered bank account or to pay in cash.

• We are doing business in a country that has a reputation for corruption.

• An Accenture agent has a family or business relationship with a public official.

• Our client asks us to make a political or charitable contribution or to use a particular subcontractor.

• An Accenture business intermediary asks for an increase in the agreed fees to close the deal.’

Supplier Standards of Conduct (February 2014), pp.5-6:

‘Accenture is committed to conducting its business free from extortion, bribery and all unlawful, unethical or fraudulent activity. Accenture suppliers comply with all applicable laws and regulations, including the U.S. Foreign Corrupt Practices Act.

In connection with doing business with Accenture, suppliers do not offer, promise, authorize, give, demand or accept any gift, loan, fee, reward or other advantage to or from any person as an inducement; to do something which is dishonest, illegal or a breach of trust; to obtain, retain or direct business; or to secure any other improper advantage. Under these standards, improper payments include offers, promises, authorizations or payments of anything of value to expedite routine government actions.

Suppliers shall implement adequate procedures for supplier employees to comply with applicable anticorruption laws and these standards.’





A18:

Does the anti-corruption policy explicitly apply to all employees and

members of the Board?

Score:

2

Comments:

Based on public information, there is evidence that the Code of Business Ethics applies to all employees and Board members.

References:

Public:






‘We are all expected to follow the Code of Business Ethics and, if we are ever uncertain about the proper course, we must raise our concerns with our supervisor, our career counselor, any member of Accenture Leadership, Human Resources, or Legal as appropriate.’

(p.4): ‘The Code of Business Ethics applies to all Accenture people—Accenture’s directors, officers and employees in every country, workforce and entity that is consolidated in Accenture’s financial statements or otherwise controlled by Accenture. In addition, while



some Accenture companies have their own codes of conduct that may supplement this document, this Code of Business Ethics also applies to employees of those entities unless the entity’s code of conduct is approved for use in lieu of Accenture’s Code of Business Ethics by Accenture’s General Counsel. With respect to entities in which Accenture has an interest but does not have control, we encourage them to adopt and follow the Code of Business Ethics as appropriate. In addition, third parties, such as consultants, agents and independent contractors, are required to comply with the Code of Business Ethics when acting on Accenture’s behalf. In certain Accenture functional areas, such as procurement, finance or on particular client engagements, more stringent requirements may apply.’


‘We expect every leader at Accenture—including our Board of Directors; Chairman & CEO; General Counsel, Secretary & Chief Compliance Officer; and Global Management Committee (GMC) members—to advocate for compliance and be a role model of the highest ethical standards.’

http://www.accenture.com/us-en/company/governance/principles/Pages/index.aspx

‘Members of the Board shall act at all times in accordance with Accenture’s Code of Business Ethics, which is applicable to all directors as well as all other Accenture personnel. This includes, in particular but without limitation, strict adherence to Accenture’s policies with respect to conflicts of interest, confidentiality, and ethical conduct in all business and personal dealings.’





A20:

Does the company have a policy on potential conflicts of interest, and does it apply to both employees and board members?

Score:

2

Comments:

Based on public information, there is readily available evidence that the company has a policy on potential conflicts of interest. It includes a definition of a conflict of interest, contains several examples and is applicable to Board members.

References:

Public:


‘5. We avoid actual and perceived conflicts of interest and ensure that our personal and financial relationships and activities do not compromise Accenture’s objectivity or reputation.’


• Our personal, social and financial activities and interests should not interfere with our objectivity and our obligation to serve the best interests of Accenture pursuant to our core values, Code of Business Ethics and policies, or compromise Accenture’s objectivity or reputation, including by creating perceived conflicts for Accenture. We don’t allow personal interests, investments, relationships and activities (including those of family members) to conflict with our work or how we serve our clients.

• Family and personal relationships in the workplace should not undermine a professional work climate. If such relationships could interfere with or potentially influence employment, including performance evaluations, promotions, career progression or work assignments, or otherwise create a perception in the workplace of inequity, bias or harassment, we must proactively consult with Human Resources.

• We never put our own financial interests ahead of Accenture’s. If we discover or create a business opportunity through use of Accenture property, information, relationships or position, we must disclose that opportunity to Accenture instead of taking it for personal


gain. We also must disclose to our supervisor any financial interests we may have (or our family members may have) that could result in any actual or perceived conflict of interest with any vendors, suppliers, clients or other third parties with which we do business. When these financial interests are disclosed, supervisors must consult with Legal to identify appropriate steps.

• We avoid conflicts of interest, and when a potential conflict does arise, you must disclose it. Reporting potential concerns is easy, and often resolvable, but you need to use sound judgment and err on the side of disclosure to your supervisor. If you doubt whether a situation raises a potential conflict, contact the Ethics Group at compliance. [email protected], your career counselor, any member of management, Human Resources or Legal to make sure you are doing the right thing.

• For more information see Policy 0015—Conflicts of Interest: Organizational, Policy 0150—Gifts and Entertainment, and Policy 1004 – Addressing Personal Conflicts of Interest.’


Family and personal working relationships

If you and someone in your household, family or personal life both work for Accenture, ask yourself:

• Does either of you exercise influence over the other at work?

• Does one of you supervise or report to the other?

• Does either of you provide input on the other’s performance, career or other business matter?

If you answer yes to any question, one of you will be required to change position or take other steps to avoid the actual or perceived conflict. An employee may not have a reporting relationship with someone in his or her personal life.’


‘Members of the Board shall act at all times in accordance with Accenture’s Code of Business Ethics, which is applicable to all directors as well as all other Accenture personnel. This includes, in particular but without limitation, strict adherence to Accenture’s policies with respect to conflicts of interest, confidentiality, and ethical conduct in all business and personal dealings. Board members must be mindful of possible conflicts of interest, including anything that could impair their independence as a director under these Guidelines, and should discuss any issues with the Chief Executive Officer, the Chairman and the Lead Director, if any. If a significant conflict arises and cannot be resolved, the director would be expected to resign. The Board is further committed to full disclosure in accordance with all applicable requirements of potential conflicts and any waiver approved by the Board.

The company will not make any loans or extensions of credit to directors. No director or immediate family member may provide personal services for compensation to the company other than Board compensation described elsewhere in these Guidelines.’

Standards of Federal Business Ethics and Conduct, 2014, p.14:



‘6.2. We avoid putting Accenture in the position of an organizational conflict of interest

The U.S. Federal Government restricts companies from serving in conflicting roles. The organizational conflict rules aim to prevent conflicting roles that might bias the contractor’s judgment or advice and to prevent an unfair competitive advantage. We take appropriate steps to recognize and avoid organizational conflicts in which our activities may preclude the pursuit of a related activity by AFS or another Accenture business segment. If we believe that we are in a conflict situation, we seek advice from Legal before we act and appropriately disclose the circumstances to the federal government. See AFS-0015 (Conflicts of Interest: Organizational).’


A21:

Does the company have a policy for the giving and receipt of gifts to ensure that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is readily available evidence that the company has a policy that regulates the giving and receipt of gifts. However, the rules of the policy are unclear, with reference made to a Gifts and Entertainment Policy that is not publically available. The company provides more detailed information for gift exchange with US federal employees. The company therefore scores 1. To score higher the company must provide evidence of clear upper limits for gift exchange and/or specific thresholds necessary for senior authorisation.

References:

Public:


‘6. We do not give or accept inappropriate gifts or entertainment.

• When seeking to provide a gift or entertainment to a third party, including public officials, regardless of value, the gift and entertainment must satisfy our five specific “gift and entertainment” criteria. Any gift or entertainment we provide to public officials (including any member of their families), commercial clients, business partners and other third parties must be: (1) for a proper purpose, and not intended to secure an improper advantage or otherwise inappropriately influence us or the recipient, (2) permitted by law, (3) permitted by our policies, (4) permitted by the recipient’s employer’s policies, and (5) reasonable in value and appropriate under the circumstances.

• When providing a gift or entertainment to a public official, we must also get prior approval under Policy 0150—Gifts and Entertainment.

• We only accept gifts and entertainment if they satisfy these same five criteria.

• For more information see Policy 0150—Gifts and Entertainment.’


Always ask yourself the following questions on gifts or entertainment:

• Would accepting the gift or entertainment violate the law?


• Would accepting the gift or entertainment violate the recipient’s organization’s policies?

• Does the gift or entertainment lack a legitimate business purpose?

• Would you be embarrassed if the gift or entertainment was made public (for example, in the papers) or if a member of the recipient’s organization’s leadership learned about it?

• Are we providing a gift or entertainment to a spouse, family member or other guest of a third party?

• Would the gift or entertainment be perceived as lavish or extraordinary given the seniority of the recipient or customary practices?

• Are you a decision-maker or influencer for the Company regarding a current or potential sales pitch, tender or bid process, or active opportunity with the company?

• Is the recipient a decision-maker or influencer at the recipient’s organization regarding a current or potential sales pitch, tender or bid process, or active opportunity?

• Is there a current or potential sales pitch, tender or bid process, or active opportunity with the recipient’s organization?’


http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-Standards-Federal-Business-Ethics-Conduct-February-2014.pdf

‘6.1. We do not provide gifts to federal government employees nor do we invite them to attend Accenture-sponsored events without appropriate pre-approval

In Accenture’s commercial business it is standard practice to offer or receive social amenities or exchange business courtesies to foster goodwill and enhance business relationships. However, when dealing with federal government employees, entertainment practices that may be acceptable in a purely commercial setting may be unacceptable or even against the law.

Federal government employees are prohibited from soliciting gifts and are subject to very restrictive rules on accepting, directly or indirectly, any gift from Accenture, due to our status as a federal government contractor.

Accenture personnel will not offer or provide gifts that, if accepted, would violate the federal government employee’s ethical obligations. A gift is defined very broadly and includes anything of value, including any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, training or other item of monetary value, whether provided in kind or through reimbursement – including meals. For example, an invitation to a sporting or other event (paid for by Accenture or the individual), could be considered a gift. Further, if a federal government employee approaches us about employment for one of their friends or relatives, the offer of such employment could be considered not only a gift, but a bribe.

We do not provide on AFS’s behalf – or engage a third party to provide on AFS’s behalf – any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, training, transportation, local travel, or lodgings and meals without first reviewing the particular situation of the intended gift with AFS Legal and receiving advance written approval. This applies regardless of whether gifts are provided directly or in-kind. In addition, note, it is the mere promise, offer or invitation that creates the thing of value, so Legal review and approval is required in advance of making any such offers.




See AFS-0150 (Gifts & Entertainment).Also see AFS-1221 (Contacts with Public Officials),’ (p.16):

‘Do’s and Don’ts of U.S. Federal Government Business Interactions

-Do consult Legal with any questions about business transactions with the federal government.

-Do commit to marketing our services and solutions solely on their merits.

-Do strive to avoid even the appearance of trying to improperly influence a government official in the exercise of his/her official duties.

-Do continue to make charitable contributions according to your own judgment and company recommendations rather than according to any federal government official’s preferences.

-Do understand that if a federal government employee approaches you about employment for one of their friends or relatives, our offer of such employment may be a bribe.

-Do get prior approval from Legal before inviting a federal government employee to an entertainment event, or offering to pay for a meal, or providing anything of value

-Do understand that merely offering anything of value with the intent to influence the awarding of a contract is illegal even if made indirectly through an intermediary.

-Do not provide or offer to provide anything of value to a federal government employee in order to influence that employee’s official action.

-Do not offer free attendance at a conference or other meeting that charges an entry fee for general admission or is sponsored by Accenture without receiving prior written approval from Legal.

-Do not offer free travel to a federal government employee without receiving prior written approval from Legal.

-Do not engage in any business activity that could suggest to an independent third-party that a federal government employee has a “conflict-of-interest.”’


A22:

Does the company’s anti-corruption policy include a statement on the giving and receipt of hospitality that ensures that such transactions are bona fide and not a subterfuge for bribery?

Score:

1

Comments:

Based on public information, there is readily available evidence that the company has a policy that regulates the giving and receipt of hospitality. However, the rules of the policy are unclear, with reference made to a Gifts and Entertainment Policy that is not publically available. The company provides more detailed information in regard to hospitality exchange with US federal employees. The company therefore scores 1. To score higher the company would need to provide evidence that it sets upper limits for hospitality exchange or specific thresholds necessary for senior authorisation.

References:

Public:


‘6. We do not give or accept inappropriate gifts or entertainment.

• When seeking to provide a gift or entertainment to a third party, including public officials, regardless of value, the gift and entertainment must satisfy our five specific “gift and entertainment” criteria. Any gift or entertainment we provide to public officials (including any member of their families), commercial clients, business partners and other third parties must be: (1) for a proper purpose, and not intended to secure an improper advantage or otherwise inappropriately influence us or the recipient, (2) permitted by law, (3) permitted by our policies, (4) permitted by the recipient’s employer’s policies, and (5) reasonable in value and appropriate under the circumstances.

• When providing a gift or entertainment to a public official, we must also get prior approval under Policy 0150—Gifts and Entertainment.

• We only accept gifts and entertainment if they satisfy these same five criteria.

• For more information see Policy 0150—Gifts and Entertainment.’










• Are you a decision-maker or influencer for the Company regarding a current or potential sales pitch, tender or bid process, or active opportunity with the company?





‘6.1. We do not provide gifts to federal government employees nor do we invite them to attend Accenture-sponsored events without appropriate pre-approval

In Accenture’s commercial business it is standard practice to offer or receive social amenities or exchange business courtesies to foster goodwill and enhance business relationships. However, when dealing with federal government employees, entertainment practices that may be acceptable in a purely commercial setting may be unacceptable or even against the law.

Federal government employees are prohibited from soliciting gifts and are subject to very restrictive rules on accepting, directly or indirectly, any gift from Accenture, due to our status as a federal government contractor.

Accenture personnel will not offer or provide gifts that, if accepted, would violate the federal government employee’s ethical obligations. A gift is defined very broadly and includes anything of value, including any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, training or other item of monetary value, whether provided in kind or through reimbursement – including meals. For example, an invitation to a sporting or other event (paid for by Accenture or the individual), could be considered a gift. Further, if a federal government employee approaches us about employment for one of their friends or relatives, the offer of such employment could be considered not only a gift, but a bribe.

We do not provide on AFS’s behalf – or engage a third party to provide on AFS’s behalf – any gratuity, favor, discount, entertainment, hospitality, loan, forbearance, training, transportation, local travel, or lodgings and meals without first reviewing the particular situation of the intended gift with AFS Legal and receiving advance written approval. This applies regardless of whether gifts are provided directly or in-kind. In addition, note, it is the mere promise, offer or invitation that creates the thing of value, so Legal review and




approval is required in advance of making any such offers.

See AFS-0150 (Gifts & Entertainment).Also see AFS-1221 (Contacts with Public Officials),’

(p.16): ‘Do’s and Don’ts of U.S. Federal Government Business Interactions

-Do consult Legal with any questions about business transactions with the federal government.

-Do commit to marketing our services and solutions solely on their merits.

-Do strive to avoid even the appearance of trying to improperly influence a government official in the exercise of his/her official duties.

-Do continue to make charitable contributions according to your own judgment and company recommendations rather than according to any federal government official’s preferences.

-Do understand that if a federal government employee approaches you about employment for one of their friends or relatives, our offer of such employment may be a bribe.

-Do get prior approval from Legal before inviting a federal government employee to an

entertainment event, or offering to pay for a meal, or providing anything of value

-Do understand that merely offering anything of value with the intent to influence the awarding of a contract is illegal even if made indirectly through an intermediary.

-Do not provide or offer to provide anything of value to a federal government employee in order to influence that employee’s official action.

-Do not offer free attendance at a conference or other meeting that charges an entry fee for general admission or is sponsored by Accenture without receiving prior written approval from Legal.

-Do not offer free travel to a federal government employee without receiving prior written approval from Legal.

-Do not engage in any business activity that could suggest to an independent third-party that a federal government employee has a “conflict-of-interest.”’


A23:

Does the company have a policy that explicitly prohibits facilitation payments?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a policy that prohibits facilitation payments. TI notes that the company’s 2010 UNGC Communication on Progress report prohibits facilitation payments and provides guidance on how this policy is to be implemented in practice. However, more recent reports or company policies do not confirm this policy.

References:

Public:

UN Global Compact : Communication on Progress, 2010, Attachment A iii-iv


‘Facilitating Payments

In some countries, employees may be asked to make relatively minor payments (typically less than US$100) to secure or expedite routine, non-discretionary governmental administrative services (so called “facilitating” or “grease” payments), e.g., to obtain permits, licenses, or other official documents; process governmental papers, such as visas and work orders; and/or receive mail and phone services. Accenture prohibits making these payments directly or indirectly (through others), even if such payments are customary, nominal in amount or even if such payments are permitted by the U.S. Foreign Corrupt Practices Act.

No Company employee or Agent may make any facilitating payments to any Public Official unless an emergency payment is necessary to address an imminent threat to the health or safety of an employee or a member of his or her family or a co-worker. Where possible, consult with and obtain approval from the appropriate Country Managing Director before making or agreeing to make any emergency payment. The Country Managing Director will determine whether the payment meets the requirements listed in this policy (prior to making the payment or if not possible, when an employee seeks reimbursement). Any approved emergency payment must be recorded clearly and accurately. The expense report




also needs to include a detailed description of the extenuating circumstances surrounding the payment, including the need for, purpose of and manner of the payment - for example: “$US100 payment to local medical hospital staff to obtain required prescription medication.”

The safety and wellbeing of our employees and their families is of paramount concern to Accenture; however, emergency payments must be limited to situations where the employee genuinely believes that he or she (or their families or co-workers) is facing an imminent threat to health or safety and no other prudent alternative is available.’


‘We do not offer or give anything of value to obtain new business, retain existing business, expedite government actions or secure any improper advantage. And we do not use others to do things we cannot do.’


A24:

Does the company prohibit political contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent? Does the company record and publicly disclose all political contributions?

Score:

2

Comments:

Based on public information, there is readily available evidence that the company prohibits political contributions.

References:

Public:


‘We exercise Accenture’s rights in the political process.

• Accenture does not endorse political candidates or make political donations. We do not use the Accenture name to endorse political activities or events or use Accenture resources to make cash or other contributions to political candidates or parties.

• Accenture advises government officials on policies that directly impact our business. Accenture takes positions on local and global policies and issues important to our business. However, as a general matter, Accenture does not take policy positions on behalf of our clients.

• Accenture does not endorse or reimburse employee political activities. While employees may make personal political contributions and be politically active, Accenture will not reimburse or endorse the political activities our people undertake as private individuals.

• We research before making personal political contributions. In some geographies, personal political contributions made by our employees can have a significant negative impact on the company’s ability to contract with government entities. Before making personal political contributions, our employees will research the relevant campaign contribution laws particularly where Accenture is a government contractor, and our U.S. employees must obtain pre-clearance before a personal political contribution is made to U.S. state or local elected officials or candidates.

• For more information, see Policy 1221—Contacts with Public Officials.’


http://www.accenture.com/us-en/company/governance/Pages/political-contributions-policy.aspx#Trade

‘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 Accenture Leaders in the U.S. 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 Managing Director of Government Relations, General Counsel, Country Managing Directors, and Operating Group Chief Executives where appropriate, have oversight over political, lobbying, grassroots lobbying communications, 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 grassroots advocacy activities and U.S. Political Action Committee.’


‘We encourage our employees to be active in civic and community activities, including participation in the political and democratic process. All political, lobbying and civic activity by Accenture and our employees must comply with applicable law and our COBE. Information related to lobbying, payments to trade associations and our political action committee can be found on accenture.com.’






A25:

Does the company have a clear policy on engagement in lobbying activities, in order to prevent undue influence or other corrupt intent, and discloses the issues on which the company lobbies?

Score:

2

Comments:

Based on public information, there is evidence that the company has a policy on engagement in lobbying activities. The Managing Director of Government Relations, General Counsel, Country Managing Directors, and Operating Group Chief Executives where appropriate, have oversight over lobbying activities, working with the company’s internal and external legal counsel as required. The Managing Director of Government Relations periodically updates the Audit Committee on the company’s lobbying and other grassroots advocacy activities. The company discloses its US federal, state and local lobbying activity and expenditures as required by law, and details the company’s 2012 annual lobbying expenses on its website.

References:

Public:


‘We exercise Accenture’s rights in the political process.

• Accenture does not endorse political candidates or make political donations. We do not use the Accenture name to endorse political activities or events or use Accenture resources to make cash or other contributions to political candidates or parties.

• Accenture advises government officials on policies that directly impact our business. Accenture takes positions on local and global policies and issues important to our business. However, as a general matter, Accenture does not take policy positions on behalf of our clients.

• Accenture does not endorse or reimburse employee political activities. While employees may make personal political contributions and be politically active, Accenture will not reimburse or endorse the political activities our people undertake as private individuals.

• We research before making personal political contributions. In some geographies, personal political contributions made by our employees can have a significant negative impact on the company’s ability to contract with government entities. Before making


personal political contributions, our employees will research the relevant campaign contribution laws particularly where Accenture is a government contractor, and our U.S. employees must obtain pre-clearance before a personal political contribution is made to U.S. state or local elected officials or candidates.

• For more information, see Policy 1221—Contacts with Public Officials.’


‘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, through our lobbyists and grassroots lobbying communications. The company discloses its U.S. federal, state and local lobbying activity and expenditures as required by law. In calendar 2012, the company disclosed (1) $2,700,000 in U.S. Federal lobbying expense and (2) $1,700,000 in lobbying expense at the U.S. State and local level. 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. Accenture does not currently make direct expenditures towards U.S. federal or state grassroots lobbying communications to the general public.’

‘The Managing Director of Government Relations, General Counsel, Country Managing Directors, and Operating Group Chief Executives where appropriate, have oversight over political, lobbying, grassroots lobbying communications, 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 grassroots advocacy activities and U.S. Political Action Committee.’




‘.3. We comply with all lobbying registration and reporting requirements

Contacts with federal government personnel for the purpose of influencing legislation, regulations or decision making may constitute lobbying, which triggers registration and disclosure requirements. If an Accenture employee or a retained consultant or someone working on our behalf, like a subcontractor, communicates with any public official or the






official’s staff, that person may be obligated to register as a lobbyist or comply with other regulations. All such personnel are responsible for understanding the applicable rules and must work with the AFS Office of Government Relations to ensure they comply.’


A25(a):

Does the company prohibit charitable contributions, or regulate such contributions in order to prevent undue influence or other corrupt intent?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company prohibits or regulates charitable contributions, in order to prevent undue influence or other corrupt intent.

References:

Public:


‘Accenture has a corporate giving program that operates largely through its foundations. We also contribute directly to local communities through corporate cash giving and pro bono services, but employees may not make contributions on behalf of Accenture and expect reimbursement.’






A26:

Does the company provide written guidance to help Board members and

employees understand and implement the firm’s ethics and anti-corruption

agenda?

Score:

2

Comments:

Based on public information, there is evidence that the company provides online guidance, to help Board members and employees understand and implement the company’s ethics and anti-corruption agenda. An interactive website provides among other things, scenarios depicting ethical dilemmas, policy information and FAQs for each action statement.

References:

Public:


‘Visit the Code of Business Ethics website for additional resources. If you have any questions about your responsibilities or any of the information in this Code of Business Ethics, please reach out to your supervisor, career counselor, Human Resources, or Legal. You can also submit any questions directly to the Ethics Group at [email protected].’

(p.24): ‘Q&A for Integrity Action Statement #6








• Are you a decision-maker or influencer for the Company regarding a current or potential

mailto:[email protected]


sales pitch, tender or bid process, or active opportunity with the company?






‘To support our COBE, we have developed an interactive COBE website, which provides access to a vast set of resources, including scenarios depicting ethical dilemmas, policy information, FAQs for each action statement, training, key terms, subject matter experts, collaboration tools and much more.’




A27:

Does the company have a training programme that explicitly covers anti-corruption?

Score:

2

Comments:

Based on public information, there is evidence that the company has an explicit anti-corruption training module as part of its ethics and compliance training programme.

References:

Public:





http://www.accenture.com/Microsites/corporate-citizenship-report-2012/corporate-governance/Pages/acn-code-of-business-ethics.aspx

‘To provide our people with a solid foundation in our Code, we require all employees to complete a minimum of one to three hours of Ethics & Compliance training annually, based on their function, location and level. In fiscal 2011, Accenture people completed more than 370,000 hours of Ethics & Compliance training, covering a wide range of topics, including personal responsibility, data privacy, information security, competition and antibribery.’

http://www.accenture.com/microsites/corporate-citizenship-report/2014/corporate-






governance/Pages/ethics-and-compliance-programs.aspx

‘We require all employees to complete several hours of Ethics & Compliance training annually on a range of topics, including our COBE, data privacy, information security and antibribery. We also conduct targeted training on specialized topics for various groups, including certain countries that require training due to local regulations, and we regularly review our audiences to determine whether we need to update or change our training.

To help ensure training topics are relevant to our employees and timely to our business, in fiscal 2012, we developed a new approach to determine employee training topics. Now, our Ethics group consults annually with senior leaders to evaluate potential topics for the full year’s Ethics & Compliance training curriculum. As part of this approach, risk assessments evaluate current business priorities, recent internal and external changes (for example, new policies or laws), current trends, time since last training and emerging risks that are most relevant to Accenture.





‘We require all employees to complete Ethics & Compliance training annually on a wide range of topics, including our COBE, data privacy, information security and antibribery. Training completion is factored into employees’ annual performance rating and/or resulting performance-based compensation. The duration and scope of training is based on employee function, location and level. Each year, we plan a full curriculum of courses that are most relevant to current business priorities and compliance risk. In fiscal 2012, Accenture people completed nearly 360,000 hours of Ethics & Compliance training.

In addition to required computer-based anticorruption training, we conduct mandatory live anticorruption training for certain employees located in higher-risk countries.’



A28:

Is anti-corruption training provided in all countries where the company operates or has company sites?

Score:

2

Comments:

Based on public information, there is evidence that the company provides anti-corruption training in all countries where it operates or has company sites. All employees must complete training annually on a number of topics, including anti-bribery training.

References:

Public:







In addition to required computer-based anticorruption training, we conduct mandatory live



anticorruption training for certain employees located in higher-risk countries.’


‘We require all employees to complete several hours of Ethics & Compliance training annually on a range of topics, including our COBE, data privacy, information security and antibribery. We also conduct targeted training on specialized topics for various groups, including certain countries that require training due to local regulations, and we regularly review our audiences to determine whether we need to update or change our training.

To help ensure training topics are relevant to our employees and timely to our business, in fiscal 2012, we developed a new approach to determine employee training topics. Now, our Ethics group consults annually with senior leaders to evaluate potential topics for the full year’s Ethics & Compliance training curriculum. As part of this approach, risk assessments evaluate current business priorities, recent internal and external changes (for example, new policies or laws), current trends, time since last training and emerging risks that are most relevant to Accenture.



Our year-long mandatory training program tracks results through ethical perception surveys, use of employee tools such as policies and the COBE site, and pre- and post-tests that demonstrate increased knowledge. Completion rates are in the high 90th percentile, which is an indicator for us of success; 100 percent is unattainable due to leaves of absence and ongoing hiring of employees. We factor Ethics & Compliance training completion into employees’ annual performance ratings and/or resulting performance-based compensation. In fact, this training is so essential to our success that, as local law permits, failure to complete required training affects employee performance ratings.’




A29:

Does the company provide targeted anti-corruption training to members of the Board?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company provides targeted anti-corruption training to members of the Board.

References:

Public:

NA


A30:

Does the company provide tailored ethics and anti-corruption training for employees in sensitive positions?

Score:

0

Comments:

Based on public information, there is evidence that the company’s ethics and anti-corruption training is based on an employee’s function, location and level. However, the company only states that in addition to computer-based anticorruption training, mandatory live anti-corruption training is provided for employees located in higher-risk countries. To score on this question the company would need to provide some evidence of those in high risk positions receiving tailored training.

References:

Public:



In addition to required computer-based anticorruption training, we conduct mandatory live anticorruption training for certain employees located in higher-risk countries.’


A31:

Does the company have a clear and formal process by which employees declare conflicts of interest?

Score:

0

Comments:

Based on public information, there is no readily available evidence that the company has a clear and formal process by which employees declare conflicts of interest. The company states conflicts of interest must be disclosed to a supervisor. If employees are unsure whether a situation is a conflict of interest, they may seek guidance from the Ethics Group, a career counselor, any member of management, Human Resources, or Legal. To score on this question the company would need to instruct employees to declare conflicts of interest, either to their managers in writing or to an independent department.

References:

Public:


‘5. We avoid actual and perceived conflicts of interest and ensure that our personal and financial relationships and activities do not compromise Accenture’s objectivity or reputation.’


• Our personal, social and financial activities and interests should not interfere with our objectivity and our obligation to serve the best interests of Accenture pursuant to our core values, Code of Business Ethics and policies, or compromise Accenture’s objectivity or reputation, including by creating perceived conflicts for Accenture. We don’t allow personal interests, investments, relationships and activities (including those of family members) to conflict with our work or how we serve our clients.

• Family and personal relationships in the workplace should not undermine a professional work climate. If such relationships could interfere with or potentially influence employment, including performance evaluations, promotions, career progression or work assignments, or otherwise create a perception in the workplace of inequity, bias or harassment, we must


proactively consult with Human Resources.

• We never put our own financial interests ahead of Accenture’s. If we discover or create a business opportunity through use of Accenture property, information, relationships or position, we must disclose that opportunity to Accenture instead of taking it for personal gain. We also must disclose to our supervisor any financial interests we may have (or our family members may have) that could result in any actual or perceived conflict of interest with any vendors, suppliers, clients or other third parties with which we do business. When these financial interests are disclosed, supervisors must consult with Legal to identify appropriate steps.

• We avoid conflicts of interest, and when a potential conflict does arise, you must disclose it. Reporting potential concerns is easy, and often resolvable, but you need to use sound judgment and err on the side of disclosure to your supervisor. If you doubt whether a situation raises a potential conflict, contact the Ethics Group at compliance. [email protected], your career counselor, any member of management, Human Resources or Legal to make sure you are doing the right thing.

• For more information see Policy 0015—Conflicts of Interest: Organizational, Policy 0150—Gifts and Entertainment, and Policy 1004 – Addressing Personal Conflicts of Interest.’


Family and personal working relationships

If you and someone in your household, family or personal life both work for Accenture, ask yourself:

• Does either of you exercise influence over the other at work?

• Does one of you supervise or report to the other?

• Does either of you provide input on the other’s performance, career or other business matter?

If you answer yes to any question, one of you will be required to change position or take other steps to avoid the actual or perceived conflict. An employee may not have a reporting relationship with someone in his or her personal life.’



The company will not make any loans or extensions of credit to directors. No director or immediate family member may provide personal services for compensation to the company



other than Board compensation described elsewhere in these Guidelines.’


‘6.2. We avoid putting Accenture in the position of an organizational conflict of interest

The U.S. Federal Government restricts companies from serving in conflicting roles. The organizational conflict rules aim to prevent conflicting roles that might bias the contractor’s judgment or advice and to prevent an unfair competitive advantage. We take appropriate steps to recognize and avoid organizational conflicts in which our activities may preclude the pursuit of a related activity by AFS or another Accenture business segment. If we believe that we are in a conflict situation, we seek advice from Legal before we act and appropriately disclose the circumstances to the federal government. See AFS-0015 (Conflicts of Interest: Organizational).’


A32:

Is the company explicit in its commitment to apply disciplinary procedures to employees, Directors and Board members found to have engaged in corrupt activities?

Score:

1

Comments:

Based on public information, there is evidence that the company has a policy to apply disciplinary procedures to all employees, Directors and Board members who violate the Code of Business Ethics. However, the company uses wording such as ‘may,’ rather than wording that signifies an explicit commitment such as ‘will.’ The company therefore scores 1. To score higher the company would need to provide evidence of an explicit commitment to apply disciplinary procedures to individuals who have engaged in corrupt activities.

References:

Public:

Code of Business Conduct, 2014, p. 4:

‘The Code of Business Ethics applies to all Accenture people—Accenture’s directors, officers and employees in every country, workforce and entity that is consolidated in Accenture’s financial statements or otherwise controlled by Accenture. In addition, while some Accenture companies have their own codes of conduct that may supplement this document, this Code of Business Ethics also applies to employees of those entities unless the entity’s code of conduct is approved for use in lieu of Accenture’s Code of Business Ethics by Accenture’s General Counsel. With respect to entities in which Accenture has an interest but does not have control, we encourage them to adopt and follow the Code of Business Ethics as appropriate. In addition, third parties, such as consultants, agents and independent contractors, are required to comply with the Code of Business Ethics when acting on Accenture’s behalf. In certain Accenture functional areas, such as procurement, finance or on particular client engagements, more stringent requirements may apply.’

(p. 5):

‘Each one of us needs to speak up when a violation of our Code of Business Ethics is

suspected. Employees who come forward with good faith concerns play a vital role

in running Accenture as a high-performance business. You can feel assured that


Accenture will not tolerate retaliation against employees for raising concerns. Accenture

investigates alleged violations of our Code and policies and disciplines violators, including

terminating their employment where appropriate.’

(p.31):

‘Any Accenture employee who has violated any part of Accenture’s Code of Business Ethics, policies or procedures may be subject to discipline, up to and including termination of employment. In addition, in some cases, Accenture may have a legal or other obligation, or may otherwise determine that it should report the results of an investigation to the appropriate law enforcement authorities.’


‘We expect every leader at Accenture—including our Board of Directors; Chairman & CEO; General Counsel, Secretary & Chief Compliance Officer; and Global Management Committee (GMC) members—to advocate for compliance and be a role model of the highest ethical standards.’

Corporate Governance Guidelines, 2011, p.4-5:

http://www.accenture.com/SiteCollectionDocuments/PDF/Accenture-Corporate-Governance-Guidelines-October-2011.pdf#zoom=50


The company will not make any loans or extensions of credit to directors. No director or immediate family member may provide personal services for compensation to the company other than Board compensation described elsewhere in these Guidelines.’


‘Accenture expects you to act ethically and comply with the law, the Code of Business Ethics and Accenture’s policies at all times. Violating the Code of Business Ethics breaks your trust with Accenture and our clients, and may result in individual disciplinary action, up to and including termination of employment, and perhaps legal liability.’






A33:

Does the company have multiple, well-publicised channels that are easily accessible and secure, to guarantee confidentiality or anonymity where requested by the employee (e.g. web, phone, in person), to report concerns or instances of suspected corrupt activity?

Score:

2

Comments:

Based on public information, there is evidence of multiple, well-publicised, secure channels, for employees to report concerns or instances of suspected corrupt activity. These channels include career counsellors, the Accenture Leadership, HR, or Legal. In particular, employees may report an ethical concern to the Accenture Business Ethics Line, which is externally operated and allows anonymous reports.

References:

Public:


Link to the Accenture Business Ethics Line.


‘• Speak up or take action. It is every employee’s responsibility to raise concerns when he or she experiences or witness unlawful, fraudulent or unethical conduct. Employees who raise concerns help us ensure Accenture continues to operate as one of the world’s most ethical—and high-performing—companies. We recognize that raising an ethical concern about someone else’s behavior can be difficult. But we all play a role in protecting what we value …our credibility with clients, our working environment, our fellow employees, our strength as a brand, our financial performance and our shareholders. Your role is critical. If you have an ethical concern, you have a right to speak up and we want you to speak up.

• Accenture will not tolerate any form of retaliation against an employee who reports an ethical concern in good faith or participates in an investigation of a possible violation of our Code of Business Ethics. If you have experienced or witnessed such retaliation, please report it.

• Raise concerns or ask questions through your line management and other trusted advisors. Whenever you have an ethical concern we want you to raise it with someone.



There are many ways to raise an ethical concern, and the most effective way may depend on the nature of your ethical concern. You can always raise an ethical concern with your supervisor, career counselor, anyone in Accenture Leadership, or anyone in Human Resources or Legal.

If you prefer, you may also report an ethical concern by using the Accenture Business Ethics Line globally at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available 24 hours a day, seven days a week (you can reverse the charges), or visit the encrypted website at https://businessethicsline.com/accenture. In most cases, you may remain anonymous when using the Business Ethics Line, however, in certain countries this may not be the case due to local legal restrictions. Please be sure to check the Business Ethics Line website for the most up to date information.

• Cooperate fully with all investigations. When reporting an ethical concern, your cooperation may be necessary so that we may adequately address your concern. While we will always respect your right to report using the Business Ethics Line anonymously (where permitted), Accenture may require or request additional information in some cases to properly investigate the matter.

• Reach out for guidance if you are approached about an ethical concern or violation of law. Speaking up is only part of the process. If you are contacted about an ethical concern or violation of law, no matter what your level, you must take the concern seriously and take action. If someone reports an ethical concern or legal violation to you, consult with your supervisor, career counselor, any member of Accenture Leadership, Human Resources or Legal to ensure it is properly handled. If someone seeks your guidance regarding an ethical concern, take the time to give them the information they need to make the right decision. If you are uncomfortable doing so or are not sure what to say, then reach out to get the guidance you need to determine the best way to address the concern. The only wrong thing to do is to do nothing.

• See 1000 - Raising Legal & Ethical Concerns and Prohibiting Retaliation for more information about how to raise an ethical or legal concern.’

(p.31): ‘How do I contact the Global Ethics Group with questions? Visit the Ethics & Compliance website or contact the Ethics Group at [email protected].’

http://www.accenture.com/us-en/company/governance/Pages/faqs.aspx

‘Q:How do I report a concern to the Accenture Business Ethics Line?

A:To report specific concerns, you should bring them to the attention of your supervisor, your career counselor, a Human Resources representative, a member of the Legal group or any member of Accenture management. Alternatively, if you prefer, you may report specific concerns regarding Accenture's financial affairs, accounting practices, auditing matters, corruption, fraud—or other serious cases where the vital interest of the company or the moral or physical integrity of our people are at stake—to the Accenture Business Ethics Line at +1 312 737 8262, available 24 hours a day, seven days a week (you can reverse the charges) or by visiting the encrypted website at https://businessethicsline.com/accenture.

You should use the Ethics Line only to make a good faith claim. Accenture takes all


http://www.accenture.com/us-en/company/governance/Pages/faqs.aspx


allegations seriously.’


‘Accenture has established several means for interested parties to communicate concerns about the company’s conduct or practices to the Board. If the concern relates to the company’s business ethics or conduct, financial statements, accounting practices or internal controls, the concern may be submitted to the Chairman of the Audit Committee, in care of the General Counsel, Secretary and Chief Compliance Officer. All such concerns will be forwarded to the Chairman for review. The company’s Code of Business Ethics and underlying policies prohibit any retaliation or other adverse action against anyone for raising a concern in good faith. If anyone nonetheless prefers to raise his/her concern in an anonymous manner, he/she may do so. The company also has established internal mechanisms for communicating concerns or questions to the company’s compliance office, including e-mail to [email protected] or by phone to the Accenture Ethics Line at 1-312-737-8262’


‘Monitoring and enforcement are integral to our corporate governance and Ethics & Compliance programs. We actively encourage employees to raise all ethics and compliance-related concerns, and we make multiple channels available for them to do so—by name or anonymously. These channels include direct supervisors and career counselors, a 24/7 Business Ethics Line and website, and Accenture Leadership—from our business, Legal and Human Resources. In all instances, we have zero tolerance for retaliation against those who raise concerns, which helps ensure our employees are comfortable speaking up.

We take every concern that is raised seriously, and we respond expeditiously. Our Corporate Investigations team, part of our Legal group, undertakes an independent, objective review and recommends appropriate remedial measures, if any. Resolution may include additional training and awareness, improvements in internal processes and controls and/or disciplinary measures. While we often handle investigations in house, we will, at times, involve third parties (such as law enforcement), where appropriate. Our standard escalation protocol for significant Code of Business Ethics matters involves members of Accenture Leadership, Legal and Human Resources, as appropriate, and calls for regular reporting to Internal Audit, our external auditors and our Audit Committee.’

https://businessethicsline.com/accenture/

‘Accenture Business Ethics Line

Encrypted website hosted by a specialist third-party service provider.’

‘You are encouraged to raise your concern directly to your career counselor, supervisor, any member of Accenture Leadership, Legal or Human Resources. If you are not comfortable raising your concerns directly through any of these channels, you may report a possible violation of our Code of Business Ethics by using this website or Accenture's Business Ethics Line at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available






24 hours a day, seven days a week (you can reverse the charges) [Note: The reporting scope of the Accenture Business Ethics Line may be restricted in some jurisdictions.*]’

‘When using this website or the Accenture Business Ethics Line, you are not required to identify yourself. However, if you choose to remain anonymous, Accenture's ability to investigate the matter may be impaired and we may not be able to fully address all of your concerns. [Note: Anonymous reporting on the Accenture Business Ethics Line may be restricted in some jurisdictions.*]’

Restrictions are in France and Austria

‘If you choose to identify yourself, your identity will be treated confidentially and shared only with a limited number of people who have a need to know or who are responsible for dealing with reports and investigations.’

Also available in French


A33(a):

Are the whistleblowing channels available to all employees in all geographies?

Score:

2

Comments:

Based on public information, there is evidence that across geographies, all employees have access to more than one reporting channel. Channels include career counsellors and the Accenture Business Ethics Line.

References:

Public:


Link to the Accenture Business Ethics Line.


‘• Raise concerns or ask questions through your line management and other trusted advisors. Whenever you have an ethical concern we want you to raise it with someone. There are many ways to raise an ethical concern, and the most effective way may depend on the nature of your ethical concern. You can always raise an ethical concern with your supervisor, career counselor, anyone in Accenture Leadership, or anyone in Human Resources or Legal.

If you prefer, you may also report an ethical concern by using the Accenture Business Ethics Line globally at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available 24 hours a day, seven days a week (you can reverse the charges), or visit the encrypted website at https://businessethicsline.com/accenture. In most cases, you may remain anonymous when using the Business Ethics Line, however, in certain countries this may not be the case due to local legal restrictions. Please be sure to check the Business Ethics Line website for the most up to date information.’


‘Accenture Business Ethics Line

Encrypted website hosted by a specialist third-party service provider.’




‘You are encouraged to raise your concern directly to your career counselor, supervisor, any member of Accenture Leadership, Legal or Human Resources. If you are not comfortable raising your concerns directly through any of these channels, you may report a possible violation of our Code of Business Ethics by using this website or Accenture's Business Ethics Line at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available 24 hours a day, seven days a week (you can reverse the charges) [Note: The reporting scope of the Accenture Business Ethics Line may be restricted in some jurisdictions.*]’


A33(b):

Does the company have formal and comprehensive mechanisms to assure itself that whistleblowing by employees is not deterred, and that whistleblowers are treated supportively?

Score:

1

Comments:

Based on public information, there is evidence that whistleblowing is encouraged by the company. Mutliple documents stress that employees must raise concerns when they witness unlawful, fraudulent or unethical conduct. However, there is no readily available evidence that the company has formal mechanisms to assure itself that whistleblowing is not deterred. The company therefore scores 1. To score higher the company would need to provide evidence of mechanisms that reduce the fear to report, such as monitoring of whistleblowing channel usage statistics.

References:

Public:


‘Accenture expects you to act ethically and comply with the law, the Code of Business Ethics and Accenture’s policies at all times. Violating the Code of Business Ethics breaks your trust with Accenture and our clients, and may result in individual disciplinary action, up to and including termination of employment, and perhaps legal liability.

• Speak up or take action. It is every employee’s responsibility to raise concerns when he or she experiences or witness unlawful, fraudulent or unethical conduct. Employees who raise concerns help us ensure Accenture continues to operate as one of the world’s most ethical—and high-performing—companies. We recognize that raising an ethical concern about someone else’s behavior can be difficult. But we all play a role in protecting what we value …our credibility with clients, our working environment, our fellow employees, our strength as a brand, our financial performance and our shareholders. Your role is critical. If you have an ethical concern, you have a right to speak up and we want you to speak up.

• Accenture will not tolerate any form of retaliation against an employee who reports an ethical concern in good faith or participates in an investigation of a possible violation of our Code of Business Ethics. If you have experienced or witnessed such retaliation, please report it.


• Raise concerns or ask questions through your line management and other trusted advisors. Whenever you have an ethical concern we want you to raise it with someone. There are many ways to raise an ethical concern, and the most effective way may depend on the nature of your ethical concern. You can always raise an ethical concern with your supervisor, career counselor, anyone in Accenture Leadership, or anyone in Human Resources or Legal.

If you prefer, you may also report an ethical concern by using the Accenture Business Ethics Line globally at +1 312 737 8262, or in India at +1 888 276 6226 with access code: 000-117, available 24 hours a day, seven days a week (you can reverse the charges), or visit the encrypted website at https://businessethicsline.com/accenture. In most cases, you may remain anonymous when using the Business Ethics Line, however, in certain countries this may not be the case due to local legal restrictions. Please be sure to check the Business Ethics Line website for the most up to date information.

• Cooperate fully with all investigations. When reporting an ethical concern, your cooperation may be necessary so that we may adequately address your concern. While we will always respect your right to report using the Business Ethics Line anonymously (where permitted), Accenture may require or request additional information in some cases to properly investigate the matter.

• Reach out for guidance if you are approached about an ethical concern or violation of law. Speaking up is only part of the process. If you are contacted about an ethical concern or violation of law, no matter what your level, you must take the concern seriously and take action. If someone reports an ethical concern or legal violation to you, consult with your supervisor, career counselor, any member of Accenture Leadership, Human Resources or Legal to ensure it is properly handled. If someone seeks your guidance regarding an ethical concern, take the time to give them the information they need to make the right decision. If you are uncomfortable doing so or are not sure what to say, then reach out to get the guidance you need to determine the best way to address the concern. The only wrong thing to do is to do nothing.

• See 1000 - Raising Legal & Ethical Concerns and Prohibiting Retaliation for more information about how to raise an ethical or legal concern.’


‘Monitoring and enforcement are integral to our corporate governance and Ethics & Compliance programs. We actively encourage employees to raise all ethics and compliance-related concerns, and we make multiple channels available for them to do so—by name or anonymously. These channels include direct supervisors and career counselors, a 24/7 Business Ethics Line and website, and Accenture Leadership—from our business, Legal and Human Resources. In all instances, we have zero tolerance for retaliation against those who raise concerns, which helps ensure our employees are comfortable speaking up.

We take every concern that is raised seriously, and we respond expeditiously. Our Corporate Investigations team, part of our Legal group, undertakes an independent, objective review and recommends appropriate remedial measures, if any. Resolution may include additional training and awareness, improvements in internal processes and controls




and/or disciplinary measures. While we often handle investigations in house, we will, at times, involve third parties (such as law enforcement), where appropriate. Our standard escalation protocol for significant Code of Business Ethics matters involves members of Accenture Leadership, Legal and Human Resources, as appropriate, and calls for regular reporting to Internal Audit, our external auditors and our Audit Committee.’


‘Monitoring and enforcement are integral to our corporate governance program and to the implementation of our zero tolerance policy. We actively encourage reporting of possible violations of our COBE or any good faith claim about Accenture’s financial affairs, accounting practices, internal accounting controls, auditing matters, corruption or fraud—or other serious matters where the vital interest of the company or the moral or physical integrity of our people are at stake. Multiple channels are available for such claims, including through direct supervisors, Human Resources, Legal and our 24/7 confidential Business Ethics Line, all without fear of retaliation.

Once a concern is raised, our Corporate Investigations team, part of our Legal group, scopes and conducts an independent and objective review, following a consistent and standard process, and recommends and implements appropriate remedial measures. Resolution may include additional training and awareness, process improvements and disciplinary measures as appropriate, up to and including termination of employment. Our standard escalation protocol for COBE concerns involves, as appropriate, senior business leadership, senior human resources leadership, senior legal leadership and regular reporting to Internal Audit, our external auditors and our Audit Committee.’


A34:

Does the company have well-publicised resources available to all employees where help and advice can be sought on corruption-related issues?

Score:

2

Comments:

Based on public information, there is evidence that the company has well-publicised resources available to all employees, where help and advice can be sought on corruption-related issues. These resources include career counsellors and the Accenture Business Ethics Line.

References:

Public:


‘We are all expected to follow the Code of Business Ethics and, if we are ever uncertain about the proper course, we must raise our concerns with our supervisor, our career counselor, any member of Accenture Leadership, Human Resources, or Legal as appropriate.’


‘As you know, not every issue that comes up has a clear path to resolution. In fact, some situations have multiple ways they can be resolved, each with its own benefits and consequences for you and Accenture, so we expect you to reach out for help. When it is clear how to apply the law or our policy, we have zero tolerance for violations. In more difficult situations that involve hard judgments between competing values, we expect you to use good judgment and to involve others to help make good decisions’

‘Visit the Code of Business Ethics website for additional resources. If you have any questions about your responsibilities or any of the information in this Code of Business Ethics, please reach out to your supervisor, career counselor, Human Resources, or Legal. You can also submit any questions directly to the Ethics Group at [email protected].’

(p.6): ‘You need to speak up when you suspect a violation of our Code of Business Ethics. Coming forward with good faith concerns is essential to running Accenture as a high-performance business. You can feel assured that Accenture will not tolerate retaliation in



any form against employees for raising good faith concerns. Accenture investigates alleged violations of our Code of Business Ethics and policies and disciplines violators, including terminating their employment where appropriate.

If you have questions about our Code of Business Ethics, you should contact the Ethics Group at [email protected], or visit the Code of Business Ethics: Our Core Values in Action website. For a full list of resources, see the Responsibilities section.’


‘Monitoring and enforcement are integral to our corporate governance and Ethics & Compliance programs. We actively encourage employees to raise all ethics and compliance-related concerns, and we make multiple channels available for them to do so—by name or anonymously. These channels include direct supervisors and career counselors, a 24/7 Business Ethics Line and website, and Accenture Leadership—from our business, Legal and Human Resources. In all instances, we have zero tolerance for retaliation against those who raise concerns, which helps ensure our employees are comfortable speaking up.’




A35:

Is there a commitment to non-retaliation for bona fide reporting of corruption?

Score:

2

Comments:

Based on public information, there is readily available evidence that the company has a clear non-retaliation policy for bona fide reporting of corruption. This includes a commitment to apply disciplinary measures to employees who breach this policy.

References:

Public:


‘Accenture will not tolerate retaliation against any employee who raises an issue or uses the Business Ethics Line (or any other appropriate channel) to report an ethical or legal concern. When we care enough to speak up and raise concerns, we build a stronger Accenture for future generations. That is the Accenture Way!’ (p.6): ‘. You can feel assured that Accenture will not tolerate retaliation in any form against employees for raising good faith concerns. Accenture investigates alleged violations of our Code of Business Ethics and policies and disciplines violators, including terminating their employment where appropriate.’ (p.15): ‘We have zero tolerance for retaliation. Accenture does not tolerate retaliation, which can come in many forms, including those that are very subtle. If you believe you are experiencing retaliatory behavior, you should immediately report it to a supervisor, career counselor, any member of Accenture Leadership or to Human Resources or Legal.’ (p.30): ‘Accenture will not tolerate any form of retaliation against an employee who reports an ethical concern in good faith or participates in an investigation of a possible violation of our Code of Business Ethics. If you have experienced or witnessed such retaliation, please report it.’ (p.31): ‘We do not tolerate retaliation against any employee because he or she genuinely reports an ethical or legal concern. Employees who retaliate against an employee who has


reported an ethical or legal concern in good faith will be subject to discipline, up to and including termination of employment. Retaliation for raising an ethical or legal concern can come in many forms and from many places, none of which is acceptable.

• It can be overt, such as receiving a cut in pay or an unjustified poor performance evaluation, being denied a promotion, being demoted or terminated, or having to endure a hostile work environment.

• It can be subtle, such as changes in work assignment or job responsibilities, or failing to share necessary information.

• It can include exclusionary behaviors, such as failing to include an employee in social events or key meetings or being denied opportunities to work on key client accounts.

• It can come from a different person than the one was the subject of the reported allegation, such as a close friend who may be in the subject’s reporting chain who engages in subtle or exclusionary behaviors such as those noted above.

The key is that any retaliatory behavior, whether overt or subtle, is unacceptable and violates our Code of Business Ethics. Like all other ethical concerns, this type of behavior should be reported.

We take all allegations seriously, including allegations of retaliation, and we resolve them in a standard, impartial process. Depending on the severity of the concern or claim that is raised, the investigative process and treatment of that claim or concern may vary. This process may take several forms, from discussions with relevant work colleagues, Accenture Leaders, or Human Resources to more formal investigations as the situation dictates. If there is a question about how a matter should be resolved, it will be referred to our Corporate Investigations team to determine whether it falls within the scope of reviewable matters requiring formal investigation, or should be referred out to another group, such as Human Resources, for resolution.

If your matter falls within the scope of review by Corporate Investigations, they will initiate scope and lead an independent and unbiased review of the matter in accordance with a standard investigative process. However, in all cases, there will be an independent review of each claim and concern that is raised with a commitment to resolving it through the most appropriate process. While for privacy reasons we can’t always disclose the actions that are taken to resolve a particular claim or concern, we take every allegation seriously and pursue an appropriate resolution.’


‘Accenture will not tolerate retaliation against any employee because they raised such an issue or used the Business Ethics Line (or any other appropriate channel) to report an ethical or legal concern.’



Information Sources:

Company website:

www.accenture.com

Code of Business Ethics (2014):


Supplier Standards of Conduct (February 2014):


Audit Committee Charter (2013):


2013 Letter from Our Chairman & CEO:


2010–2011 Corporate Citizenship Report Summary (2012):


UN Global Compact: Communication on Progress, 2011:


http://www.accenture.com/













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