Code of Business Ethics: Our Core Values ni Action

Code of Business Ethics: Our Core Values ni Action

2 | Accenture Code of Business Ethics Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

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. 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.

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!

Introduction

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Accenture Code of Business Ethics

Pierre Nanterme—To All Accenture People

Chad Jerdee—A Message from Our Chief Compliance Officer

Our Code at a Glance

Client Value Creation

One Global Network

Respect for the Individual

Best People

Integrity

Stewardship

Your Responsibilities

Accenture’s Responsibilities 31

Table of Contents




To Whom Does the Code of Business Ethics Apply?The Code of Business Ethics applies to all Accenture people—Accenture’s directors, officers and employees in every country,

kcart reerac 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. If you are not sure of Accenture’s expectations of you or any third party you may be working with, talk to your supervisor or the Ethics Group at [email protected].

What Does “Living” the Code Mean: Our Core Values in ActionOur 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.

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.

Accenture Code of Business EthicsYou have a personal responsibility to act ethically and comply with the law. The Responsibilities section of the Code of Business Ethics describes Accenture’s expectations of you and what you can expect of Accenture.

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].



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5 | Accenture Code of Business Ethics

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.

Pierre Nanterme Chief Executive Officer

To All Accenture People

Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website



6 | Accenture Code of Business Ethics

Chad Jerdee General Counsel and Chief Compliance Officer

A Message from Our Chief Compliance Officer

Accenture’s growth and success ultimately depend on the decisions we make at work every day. We each have the responsibility—for our colleagues, our clients, our communities, and our company—to operate with the highest integrity and in compliance with the laws and regulations wherever we do business.

Mutual respect, fairness, and a commitment to ethical behavior are at the center of our core values and Code of Business Ethics. Our conduct also reflects who we are and who we want to be as a company, and how we work with clients and each other, the Accenture Way.

Conducting our business this way is more than an operational requirement—and it’s more than policies and processes—it’s a dynamic, strategic driver of our success. It creates an environment where our people operate at their full potential to help grow our business; it differentiates us to support an ethical and respectful culture that enables us to attract and retain top talent; and it provides protection for our people, our brand and our financial performance.

Our “Code of Business Ethics: Our Core Values in Action” explains how we can live our core values so that each of us can help drive Accenture’s success. It describes how we can apply our core values every day, and “action statements” capture what we must do to comply with the law, as well as Accenture policies and practices. It also shows us how to be good corporate citizens, emphasizing the importance of continually striving to make a positive contribution in the communities where we work and live.

We want you to speak up if you have a genuine concern about disrespectful or inappropriate conduct, or unethical or illegal behavior of any kind. We have zero tolerance for retaliation against anyone who speaks up in good faith. Retaliation means any kind of unfair treatment, whether subtle or overt. There are serious consequences for retaliation– up to and including termination, where appropriate.

There are many ways to raise a concern, and the most effective way will depend on the nature of the situation and your concern. For more information, please see Respecting the Individual (Policy 1001).

If you have questions about our Code of Business Ethics, please 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. Thank you for your efforts to make your conduct count by living our core values and Code of Business Ethics…the Accenture Way.

Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website



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Our Code at a Glance

One Global Network in actionLeveraging the power of global insight, relationships, collaboration and learning to deliver exceptional service to clients wherever they do business.1. We create competitive advantage and

differentiated thought leadership bycollaborating, teaming and sharing ourknowledge and expertise across our globalorganization.

2. We rise above organizational, cultural andgeographic boundaries to match the rightperson to each role, striving to apply the bestof our company’s talent to help our clientsachieve high performance.

3. We run our company as a truly globalbusiness, applying consistent globalstandards and leveraging valuable globalreach—while being responsive to each client’sindividual needs.

4. We respect the cultures in the countrieswhere we work and nurture meaningfullocal relationships while leveraging globalcapabilities and adhering to our core valuesand ethics.

5. We protect and enhance our global brandby operating ethically, delivering consistentvalue and quality, and speaking with aconsistent global voice.

6. We work to ensure that Accenture Leadersrepresent the global nature and diversity ofour company.

7. We protect the privacy of personal data andcomply with data privacy and protectionlaws.

8. We comply with international trade laws.

9. We do not seek out or use competitors’confidential information.

Respect for the Individual in actionValuing diversity and unique contributions, fostering a trusting, open and inclusive environment and treating each person in a manner that reflects Accenture’s values.1. We treat each other with respect, maintain

a safe and nonthreatening workplace anddo not tolerate harassment or disrespectfulbehavior of any kind.

2. We are inclusive—we pursue diversity as anorganizational priority, respect all employeesequally and value the contributions of eachperson and role.

3. We recognize people for their contributionsand provide timely, open and honestperformance feedback.

4. We share a mutual commitment to supporteach other’s growth, career development andwork/life balance.

5. Our leaders engage in honest, opencommunication and foster mutual trust.

6. We listen to our colleagues’ points of viewand encourage authentic, genuine leadershipat all levels.

7. We demonstrate trust in others by believingin their capabilities and intentions, settingclear expectations, holding them accountableand delegating decision making, asappropriate.

8. We enthusiastically help others when theyare in need and we are there for each other,both professionally and personally.

*Action statements are numbered for ease of identification only.

Client Value Creation in action Enabling clients to become high-performance businesses and creating long-term relationships by being responsive and relevant and by consistently delivering value.1. We focus on sustainable, long- term

outcomes, forgoing short-term opportunitiesthat are inconsistent with our goal ofdelivering long-term value.

2. We bring the best of Accenture to each clientby leveraging and integrating our range oftalents and by sharing our deep experienceglobally to create predictable outcomes.

3. We build long-term relationships withour clients by listening to their needs,understanding their aspirations and diversecultures, and delivering value to help themachieve high performance.

4. We value innovation and anticipate futureneeds—enabling us to differentiate ourcapabilities and remain relevant to clientsunder changing business conditions.

5. All Accenture people serve Accenture’sclients, regardless of kcart reerac or role—acting in the best interests of our clientswhile safeguarding our company.

6. We commit to what we can deliver and wedeliver on our commitments.

7. We leverage proven methodologies andcomprehensive capabilities to achievedelivery excellence for clients.

8. We seek to understand and follow clients’codes of conduct along with Accenture’sCode of Business Ethics.

9. We comply with government contracting andprocurement regulations.

10. We purchase goods and services based ontheir merits.

11. Quality drives client satisfaction, profitabilityand our stature in the marketplace.

Living the Code of Business Ethics: Our Core Values in Action




Integrity in actionBeing 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 opendebate, gives everyone a voice and enablespeople to raise issues without fear ofretaliation.

2. We build trust-based relationships throughconsistent ethical personal conduct and byliving our core values.

3. We prepare and provide accurate, timely andcomplete reports for our clients and otherstakeholders.

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

5. We avoid actual and perceived conflictsof interest and ensure that our personaland financial relationships and activities donot compromise Accenture’s objectivity orreputation.

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

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

8. We are fierce but fair competitors.

9. We handle “inside information” appropriatelyand lawfully.

10. We comply and cooperate fully withinvestigations, ongoing litigation and audits.

11. We use electronic technology responsibly andprofessionally.

12. We are respectful and professional whenusing social mediasites.

Stewardship in actionFulfilling 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 environmentallyresponsible.

2. We balance the short-term demands of ourbusiness with the long-term needs of thecompany and make investments to enhanceshareholder value.

3. We are entrepreneurial, act as owners ofthe company, make decisions within ourauthority and use informed judgment to takeappropriate risks.

4. We invest time and resources in preparingour next generation of leaders, while strivingto mirror the global and diverse nature of ourmarketplace.

5. We operate the company so that we achievehigh performance generation to generationas well as from year to year.

6. We expect Accenture people to put thebroader interests of the entire companyahead of the individual interests of a groupor function.

7. Our leaders communicate and demonstrate ashared vision and a commitment to strategicpriorities—helping employees understandhow individual roles contribute to our overallsuccess.

8. Accenture is a good corporate citizen andencourages the active involvement ofemployees in the communities where wework and live.

9. We invest in Accenture’s assets, safeguardAccenture’s proprietary and confidentialinformation, and protect and defendAccenture’s intellectual property.

10. We exercise Accenture’s rights in the politicalprocess.

Best People in actionAttracting, 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.

1. We seek to understand different points ofview and foster a fair, positive, inclusiveenvironment in which people with diversetalents and backgrounds can confidentlygrow and succeed.

2. We help individuals develop specializedskills—encouraging them to take on greaterresponsibility and enabling them to grow inconfidence, competence and marketplacerelevance.

3. We leverage the unique attributes ofindividuals to create dynamic, innovativeteams.

4. We reward leadership excellence and wevalue the leadership contributions of all ourpeople—people developers, value creators andbusiness operators.

5. We encourage collaboration by fosteringtrust, shared goals and mutual accountability.

6. We invest in our people and their careergrowth by encouraging continual learningand by creating opportunities that supportnear-term developmental needs and long-term career progression.

7. Accenture supports our people who choose tovolunteer their time and skills for the benefitof communities and the environment.

8. We are responsible for managing our owncareers and pursuing our personal definitionsof success.

9. We do not ask our people to compromisetheir personal values nor their professionalobligations, such as confidentialityobligations to former employers.

*Action statements are numbered for ease of identification only.

Our Code at a GlanceLiving the Code of Business Ethics: Our Core Values in Action



9 | Client Value Creation Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

Client Value Creation

1. We focus on sustainable, long-term outcomes, forgoingshort-term opportunities that are inconsistent with our goalof delivering long-term value.• Honest relationships unlock long-term value. To help clients become

high-performance businesses and governments, we need long-term,collaborative relationships. When clients rely on us and trust us, theyshare their interests, which allows us to deliver real value.

• We match our solution to what a client needs. We seek tounderstand our clients’ underlying interests and tailor our sales strategyto meet clients’ business objectives.

• We have a deep understanding of our client’s needs. Acting in aclient’s best interests does not mean saying yes to anything the clientasks for, particularly if it does not meet the client’s long-term interests.

2. We bring the best of Accenture to each client byleveraging and integrating our range of talents and bysharing our deep experience globally to create predictableoutcomes.• We have unmatched experience across industries and business

functions because our people are devoted to their areas of expertise. Wemobilize the best people in the right place at the right time.

• We do not assume perfection. As professionals we know that clientvalue comes from well-planned and executed work, including havingothers review our work and being transparent about challenges we face.

• We assume good intentions in each other. We earn each other’s trustand team effectively for our clients when we are clear in our intentions,meet our commitments and deliver predictable results. Mistrust hindersour ability to create client value—it impedes effective teamwork and ourclients can see it, which undermines their faith in us.

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




3. We build long-term relationships with our clients bylistening to their needs, understanding their aspirations anddiverse cultures, and delivering value to help them achievehigh performance.• A strong relationship means managing differences. The quality

of a client relationship depends on how well we handle differences.Our clients freely debate with us and rely on us to be honest withthem. They expect us to collaborate to make joint decisions and to betransparent in our interactions.

• You can’t listen if you’re talking. Because two people can reachdifferent conclusions from the same pool of data, we strive to listenactively and confirm that we understand the other person’s interests.

• We win our clients’ confidence by being credible and reliable.Clients expect us to understand their unique challenges andopportunities and to have hands-on experience of their needs. Butcredibility alone isn’t enough to earn their trust. We must serve theirinterests consistently and reliably—which ultimately meets our interests.

• We remain unconditionally constructive. When clients disagreewith us and we feel emotional, we try to identify their true underlyinginterests, rather than just their stated positions. We remain principled,reasonable and consistent to ensure the conversations are constructiveand to forge enduring client relationships.

4. We value innovation and anticipate future needs—enabling us to differentiate our capabilities and remainrelevant to clients under changing business conditions.• Most innovations are not an earth-shattering, out-of-the-blue

stroke of genius. Rather, they are built upon incremental creativeimprovements—such as a more efficient step in a process.

• We integrate our expertise in a cycle of ingenuity. Specializedgroups develop capabilities that others use and innovate for particularclient outcomes. We then harvest those innovations and feed them backto the experts, who further hone their expertise. This cycle keeps ourcapabilities fresh, cutting-edge and relevant.

• We restlessly look around corners. We aim to sustain highperformance over time, business cycles, changes in leadership andmarketplaces. While we take pride in trying to be the best today, wewant to be even better and more relevant to our clients tomorrow.

5. All Accenture people serve Accenture’s clients, regardlessof kcart reerac or role—acting in the best interests of ourclients while safeguarding our company.• We ask why. We probe to understand the client’s interests and why

they want something, then we create solutions that satisfy Accenture’sinterests as well.

• Creating value creates revenues. The value we create for our clients—improved efficiencies, strategic transformations and long-term savings—generates the pool from which we are paid. The bigger the pool, themore we can expect to earn.

• Internal teams serve external clients. Every internal team starts froma business goal. “What are we trying to accomplish on behalf of thebusiness of Accenture? How does that translate into our particularobjective?” We serve internal clients so that the company can betterserve external clients.

Q&A for Client Value Creation Action Statement #3

The client’s chief information officer really wants us to do a project but does not have a business case. I do not think it is the right thing for the client. What should I do?You should decline a project when you don’t believe it will generate real value for a client. We actually gain credibility with a client organization when we challenge proposals or requests that are unlikely to solve the business problem. Being honest and courageous is not only the right thing to do, but it saves us from inevitable criticism later from the client’s CEO, who could say, “Why didn’t you tell me?” Such criticism weakens the client relationship and undermines our reputation.




6. We commit to what we can deliver and we deliver on ourcommitments.• We keep promises. Accenture’s size, scope and talent mix often require

different people to sell, negotiate and deliver our services. We do notmake commitments for others before they agree to be held accountablefor them—our business relationships endure and prosper because they arebased on mutual respect and trust.

• The right person or team makes the ultimate decision. Whenpursuing an opportunity or planning a project, we balance collaborative,efficient and informed decision making among key stakeholders with theaccountabilities described in our operating model.

• Our business has limits. Even though we offer extensive capabilities, weare aware of the limits on the scope of our business and seek appropriateapprovals before committing to expand that scope into new lines ofbusiness or new geographies.

• Words and actions must match. We strive to do what we say we willdo, when we say we will do it, in the way we say we will do it.

7. We leverage proven methodologies and comprehensivecapabilities to achieve delivery excellence for clients.• Creativity feeds delivery, which feeds innovation. Accenture depends

on the innovative spirit of our people to generate improvements—thedifferentiated architectures, systems, methods and applications that fuelour growth as we reuse and redefine these valuable assets.

• We deliver what others struggle to master. We strive for consistentdelivery, which means achieving the outcome we promised. Whileothers may strain to execute the more complex services that sometimesoverwhelm them, we deliver through disciplined execution.

• We don’t give our assets away. Our assets differentiate Accenture andrepresent a significant investment. Clients pay us for the results of thoseinnovations, not for the rights to the assets themselves. We must retainthose rights to leverage in our future business.

8. We seek to understand and follow clients’ codes ofconduct along with Accenture’s Code of Business Ethics.• It’s our responsibility to understand a client’s code of conduct in

addition to following our own Code of Business Ethics. A client’s codeof conduct sets expectations about how it expects its employees, andoften its business partners, to behave. There may be restrictions on, forexample, gifts, entertainment and physical security that are more limitingthan our own, and if so,we must follow them in connection with theclient engagement. By following a client’s code of conduct, we can notonly deliver more effectively and productively in that client’s environment,but also help instill confidence in our practices. However, if our clientdoes not have a code of conduct, or its requirements are less stringentthan our own, you must always adhere to Accenture’s Code of BusinessEthics.

• When compliance is not possible, we discuss with the client. Aclient’s code of conduct may appear to contradict our own Code ofBusiness Ethics—for example, it may include requirements we cannotfollow (because of practical limitations on how we do business) orprovisions that do not apply to us. When faced with such situations, wewill discuss with the client as appropriate and seek to comply with thespirit or key principles of its code, while always following Accenture’sCode of Business Ethics.

• When compliance is not possible, we also expect you to escalate:discuss with your management, Human Resources or Legal to resolve theissue—for example, we may need to include limitations or clarifications inour client agreements to comply with the obligations under the client’scode of conduct.

9. We comply with government contracting andprocurement regulations.• The meaning of “government” is broad. Government clients may

include traditional government agencies as well as commercial for-profitentities that are controlled or owned by governments (even partiallyowned).

• Doing business with governments is very different from doingbusiness with commercial clients. We understand and comply with thelegal requirements and restrictions that apply to pricing and deliveringour services to government clients.

10. We purchase goods and services based on their merits.• We are careful buyers. Accenture purchases goods and services based on

price, quality, performance and suitability. We do not buy from our clientsjust because they are buying from us. Accenture has assigned people tomake decisions about purchasing, paying invoices and signing suppliercontracts.

• We use standard processes and preferred supplier contracts that havebeen put in place by our procurement organization. When we enternew supply agreements, we reasonably balance value and risk. We arecommitted to a sustainable procurement program in which we considera supplier’s environmental, ethical and diversity performance when wedecide to award work.

• We avoid questionable transactions. We avoid transactions that mayappear to be improper or illegitimate or that may misrepresent theaccounting reports or results of any party to the transaction.

• We hold our suppliers to high standards. Our suppliers must act in amanner consistent with Accenture’s Supplier Standards of Conduct, whichis built on Accenture’s core values and advocates responsible businesspractices.

11. Quality drives client satisfaction, profitability and ourstature in the marketplace.• We define quality as conformance to promised outcomes—how well

we hit the target and deliver the promised outcomes for our clientsand for each other. Once we identify the desired outcomes—by clearlyunderstanding our client’s business case, needs and expectations—wecreate the right solution plan, capability plan and contract, all within theprice constraints.

• We are holistic in our assessment of risk. We want to anticipate, assessand manage risk in a thoughtful and transparent way. While we seek toalign all elements of the deal, we recognize that our complex businessenvironment can prevent this alignment. We therefore create thoughtfuland robust risk management plans that clearly identify the risks with thecorresponding mitigating actions and ownership by named individuals foreach action. We also establish solution contingency based on the risksand the confidence in our mitigation plan.

• Quality is a source of pride and satisfaction that all of us derive fromthe work we do for our clients.



12 | One Global Network Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

One Global Network

1. We create competitive advantage and differentiatedthought leadership by collaborating, teaming and sharingour knowledge and expertise across our global organization.• Our people, processes and assets drive our competitive edge. Our

highly trained, skilled people and market-relevant assets allow us tooutperform our competitors. Our people collaborate and share theirknowledge across the organization to build skills and drive innovation,helping us stay relevant to our clients’ needs.

• We bring our clients the best of Accenture. Through the power ofour collaboration and knowledge-sharing capabilities, our employeestap into the global network of people, thought leadership and offeringsto deliver efficient, exceptional service to clients wherever they dobusiness.

2. We rise above organizational, cultural and geographicboundaries to match the right person to each role, strivingto apply the best of our company’s talent to help our clientsachieve high performance.• We build optimal teams to deliver client value. We combine

people with different expertise from different entities and locations toassemble in-person and virtual teams. Organizational and geographicboundaries should not stop us from making the right decisions.

• We help each other. Accenture’s collaborative culture means we willcontact people we have never met to access their expertise or insight.We respond to those requests enthusiastically, recognizing that we aretrying to meet our clients’ needs.

• We solve for Accenture. We want to support local business targets,but we also need to “solve” for Accenture as a whole, which requiresbalancing competing priorities.

3. We run our company as a truly global business, applyingconsistent global standards and leveraging valuable globalreach—while being responsive to each client’s individualneeds.• Like us, our clients continuously evolve. We use our common

core values and methodologies to work effectively across differentgeographies, cultures, skcart reerac and generations to meet our clients’needs.

• We aim to be local leaders. Our goal is to be recognized as a leaderin the business community in each country in which we operate, whilemaintaining the consistency in point of view required of a truly globalcompany.

• We comply with all laws, whether local, national or regional.Accenture people, including others acting on our behalf, are responsiblefor understanding the applicable rules and must work with Legal toensure compliance.

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




4. We respect the cultures in the countries where we workand nurture meaningful local relationships while leveragingglobal capabilities and adhering to our core values andethics.• Accenture’s core values and ethics are global. Because some business

cultures have practices that may violate them, upholding our corevalues may be uncomfortable, even painful, but doing the right thingoften requires courage. Saying no to these practices does not mean wedisrespect those cultures.

• Our clients expect each of us to understand their industry,regardless of our career level. We invest in staying current anddeveloping business relationships through meaningful membershipsin professional organizations and associations where we can positionAccenture well.

5. We protect and enhance our global brand by operatingethically, delivering consistent value and quality, andspeaking with a consistent global voice.• We are the Accenture brand. The Accenture name and brand are

powerful and valuable assets that differentiate us from our competitors.Our individual behavior and business decisions, as well as the businessdecisions we make as a company, advance our brand consistently acrossthe world.

6. We work to ensure that Accenture Leaders represent theglobal nature and diversity of our company.• We value different cultures. We believe cultural awareness is a two-

way street. We train new joiners on Accenture’s culture and we trainour current employees to understand the cultures of our new joiners.People of different backgrounds and experiences have different ways ofthinking and together usually generate more creative answers. It makesgreat business sense to embrace these differences.

• We understand cultural differences. In some cultures respect forleadership can make it difficult for more junior people to disagree orprovide critical feedback, so we work hard to create an environmentwhere people can feel comfortable raising their concerns. We encouragepeople to share their thoughts and challenging ideas, which meanshelping them speak up. We do not judge anyone struggling with Englishor Accenture terminology.

• We strive to have a diverse workforce and we meet legal hiringmandates where required.

7. We protect the privacy of personal data and comply withdata privacy and protection laws.• We use personal data responsibly. There must be a legitimate,

compelling business purpose for any use or sharing of personaldata. Various laws and our client agreements determine how we useand share data when we are delivering our services, and we in allcircumstances must abide by these requirements. We also must assessthe impact of data privacy requirements when designing new servicesand offerings. See Policy 0090—Data Privacy for more information.

• We protect personal data. We protect personal data physically andelectronically and do not place personal data on unencrypted computersand removable media (flash drives, backup drives, CDs). We securelaptops and other portable media. We only store paper hard copiesof personal data (for example, credit card numbers, financial accountdata and health information) in secure environments and for as longas reasonably necessary. We never take any client or Accenturepersonal data with us when we leave Accenture. See Policy 1431—DataManagement for more information.

Q&A for One Global Network Action Statement #7

Data privacy laws only cover sensitive personal data, like ethnicity, medical data, credit card numbers and pension account numbers, right?Wrong. Data privacy laws and Policy 0090 apply to much more and include e-mail addresses, business and home contact details, opinions about individuals, their preferences, their voice and image—these are all personal data protected by data privacy laws and Policy 0090. As long as such data can be linked to an identifiable individual, it is personal data.



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8. We comply with international trade laws.• International trade laws have global reach. Accenture complies with

all applicable international trade laws in the countries in which weoperate, including export controls, economic sanctions and anti-boycottlaws. These legal requirements govern the worldwide transfer of goods,technology and services, and restrict where and with whom we dobusiness, depending on the nature of the activities, the countries andthe parties involved. In addition, international activities involving highlyregulated areas such as defense and nuclear energy may require exportlicenses or other forms of government authorization.

• See Policy 1283—Compliance with Export Control and Anti-BoycottLaws for more information.

9. We do not seek out or use competitors’ confidentialinformation.• Accenture recognizes the importance of lawfully collecting

information on our competitors. However, employees should obtainthat information in a professional and ethical manner and avoid anyperception of improper behavior.

• We never obtain information about a competitor through the useof unlawful or unethical means, such as misrepresentation, deception,theft, espionage, bribery, or by requesting improper disclosure by acompetitor’s employees, suppliers or clients. We do not use others to dothings we cannot.

• New hires keep their previous companies’ secrets. We do not askemployees who have worked at our competitors for confidential orproprietary information. Our people keep private such information abouttheir prior work experience.

• Gathering competitive information has strict rules. The impropercollection or use of competitive information, no matter howinsignificant, could subject employees and the company to criminal andcivil liability.

• See Policy 0069—Confidentiality for more information.





https://policies.accenture.com/Pages/0001-0100/0069.aspx?rd=1&Country=USA

15 | Respect for the Individual Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

Respect for the Individual

1. We treat each other with respect, maintain a safe andnon-threatening workplace and do not tolerate harassmentor disrespectful behavior of any kind.• We expect others to treat us fairly and respectfully. Each of us is

entitled to work in an environment free from harassment, unlawful orunfair discrimination, and disrespectful behavior.

• We expect a professional environment where we can grow andsucceed. Harassment in any form and disrespectful behavior areprohibited.

• Accenture Leaders are role models whose behavior must at all timespromote a respectful working environment. In addition, AccentureLeadership must take appropriate action if they see or become aware ofharassment, unlawful or unfair discrimination or disrespectful behavior.

• We make personal safety a top priority. We follow all safety andemergency procedures at our facilities and at client sites. We create anenvironment free of violence, weapons and other disruptive behavior.To protect Accenture, our people and our assets, Accenture may askto search personal property at a company worksite, and to the extentpermitted by law, may monitor at any time all Accenture assets,including e-mail, instant messaging and Internet usage.

• Speak up if you have a concern. Employees who raise or reportconcerns help us maintain our respectful and professional workplaceand high-performance business, preserve our client and third-partyrelationships, and avoid potentially serious liability. If you believe youhave experienced harassment or other disrespectful behavior, or havewitnessed it (whether by a colleague at Accenture or a third party wework with such as a client or vendor), we encourage you to raise yourconcerns through one of the available channels.

• We have zero tolerance for retaliation. Accenture does not tolerateretaliation, which can come in many forms, including those that arevery subtle. If you believe you are experiencing retaliatory behavior,you should immediately report it to a supervisor, career counselor, anymember of Accenture Leadership or to Human Resources or Legal.

• See the Your Responsibilities Section and Policies 1001 - Respecting theIndividual and 1000 - Raising Legal & Ethical Concerns and ProhibitingRetaliation for guidance.

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



https://policies.accenture.com/Pages/1001-1100/1001.aspx





Q&A for Respect for the Individual Action Statement #1

What is harassment or disrespectful behavior?Harassment and disrespectful behavior can take many forms, including abusive and bullying behaviors, inappropriate comments and unfounded criticisms, retaliation, excessive swearing or shouting, repeated and blatant disregard for employees’ personal time and commitments, or unwanted physical touching. Examples of these prohibited behaviors may include:• something someone says or does (or does not say or do), whether in person

or remotely• an e-mail, letter or document• a posting on the Internet or intranet (e.g., on Facebook, a blog or a tweet)• a message sent by instant messenger or Office Communicator

• a physical gesture

and the prohibited behavior or treatment might involve:• repeated shouting at employees in public or private• excessive use of profanity/swearing directed towards an individual and/or an

individual’s work products• targeted vulgarity and rudeness, personal insults or name-calling• uncontrollable and threatening anger directed towards an individual• repeated, blatant disregard by an individual for another person’s personal

time• spreading rumors with a deliberate intention to cause harm to an individual• deliberate and blatant disrespect to cultural differences• deliberate exclusion or continued isolation from work social activities• displays of offensive material• offensive jokes• repeated requests for meeting up socially (after the recipient has made clear

that these requests are unwanted), repeated unwanted displays of affection,or other repeated unwanted attention

• unwanted physical contact (whether or not of a sexual nature)• abuse of authority (including use of intimidation, threats, blackmail,

coercion, or requiring an individual to perform purely personal errands ortasks)

• threats of dismissal, negative impact on rating, loss of promotion, deprivingsomeone of work opportunities or other negative consequences, whichare not consistent with our principle of meritocracy, as set out in ourMeritocracy policy - Policy 1003 – Living our Principle of Meritocracy

• persistent, unjustified and/or unnecessary negative attacks on a person’spersonal or professional life

• bullying or abusive behavior (in each case, by one or more individuals);‘bullying’ means behavior, directed against someone, that is intimidating,offensive or malicious and that undermines the confidence and self-esteemof that person

• public or private humiliation and/or intimidation• threatened or actual violence whether or not directed at an individual





2. We are inclusive—we pursue diversity as an organizationalpriority, respect all employees equally and value thecontributions of each person and role.• Creative thinking should not stay locked inside because people

look different or speak differently than we do. We understand thattremendous value resides in every person, so we engage each other withrespect, regardless of differences.

• Leaders set the tone. All Accenture teams include people who maybe profoundly different from each other. When a leader tolerates badbehaviors—lack of respect, impatience, discrimination—the team oftenfollows. Leaders recognize the power of their behavior and ensure thatteam members respect each other and are encouraged to contribute.

• Leaders don’t have all the answers. In a world where clients demanddeeper, specialized skills, junior team members often may have betterideas than their leader. The successful leader has the self-awareness,team focus and humility to proactively draw out the team’s diverseperspectives.

3. We recognize people for their contributions and providetimely, open and honest performance feedback.• Our feedback is fair and helps individuals improve their

performance. We are honest with each other formally—duringperformance evaluations— and informally, as part of day-to-day life.Feedback must be truthful, to the point, factual and helpful. We wantour leaders and supervisors to continually provide timely and candidfeedback to our people.

• Everyone can improve. Even top performers can improve. Givenappropriate coaching and feedback, others can be tomorrow’s topperformers.

4. We share a mutual commitment to support each other’sgrowth, career development and work/life balance.• We succeed when others succeed. Accenture credits people for

developing others. We have a strong career counselor system, and weencourage mentoring relationships, particularly as we rise throughthe organization, to make sure that people have access to advice onboth day-to-day issues and strategic coaching on areas outside theirparticular area.

• Accenture encourages leaders to model work/life balance and allemployees to be respectful of work/life balance needs. We shouldwork together to find solutions to meet the needs of our business andeach other.

• We take time to give. As part of our corporate citizenship initiative,Accenture encourages people to take time to volunteer, serve onnonprofit boards and participate in pro bono projects and otheractivities.


What does diversity mean for Accenture, a global company?We take a wide view of diversity. We realize that all of our people bring distinct experiences, talents and perspectives to their work, and we capitalize on that diversity—collaborating with each other so that we can help our clients achieve high performance.

Our diversity efforts ensure we attract, retain and advance the best people by removing barriers and promoting a true meritocracy. Combining multiple perspectives from our diverse global culture with our common values and methodologies is a powerful differentiator for Accenture.




5. Our leaders engage in honest, open communication andfoster mutual trust.• We foster open communication and encourage people to ask for

help. We reach out for support whenever we are struggling or needhelp.

• We tell the truth. Transparent communication leads to understanding,which leads to trust. If something is in the best interest of the company,but not an individual employee, we still strive to tell the truth, eventhough it can hurt. Some decisions are difficult to communicate, but weaim to be clear about our intentions and confident in our delivery.

6. We listen to our colleagues’ points of view and encourageauthentic, genuine leadership at all levels.• We listen. Good communication means listening more than we

speak. We listen to understand each other’s interests and respondconstructively to different opinions. Listening means demonstrating thatyou understand.

• Leaders have an authentic style. We expect leaders, regardless ofcareer levels, to find their own personal and genuine approach toleadership, to live it, explain it and share it with their teams, and tomodel tolerant behavior.

• Everyone should lead with humility. We are leaders of teams, ofpoints of view, of areas of expertise, and of our own behavior. We areresponsible for drawing out the best in each other, for understandingour own limitations and for reaching out to collaborate when necessary.

7. We demonstrate trust in others by believing in theircapabilities and intentions, setting clear expectations,holding them accountable and delegating decision making,as appropriate.• We have faith in each other’s capabilities. We assign tasks and

delegate decisions to people at all career levels because we trust thatothers are competent and accountable. The most successful teamsassemble experts from different areas and then delegate that particularpart of the work to them to deliver, supporting them in the process.

• We set clear objectives for our people. We know what we are beingasked to do or, if we don’t, we strive to learn as quickly as possible. Wemeasure people against business objectives, rate people relative to theirpeers and hold each other accountable for what we actually achieve.

• We believe in each other’s initiative. We believe our people wantthe company to do well and that their own performance impacts thecompany performance. We encourage each other to stretch and pursueopportunities within or just beyond our capabilities.

8. We enthusiastically help others when they are in needand we are there for each other, both professionally andpersonally.• We care about each other. If a colleague needs help, we respond

willingly, listening to them, advising them, showing genuine interest,respect and understanding.

• Each of us is a wealth of resources. No matter what our level, eachof us has expertise or experience that someone else would like to tapinto. We are open to others looking for guidance or ideas to pursue anew direction. We willingly offer our resources to help them meet theirgoals, which may include reaching out across skcart reerac , geographiesor organizations.


What are the expectations of our leaders?At Accenture, we are committed to developing strong leaders at all levels of our company.

We focus on three leadership contribution areas: value creator, business operator and people developer, and we expect our leaders to develop and contribute in a balanced way across these three areas.



19 | Best People Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

Best People

1. We seek to understand different points of view and fostera fair, positive, inclusive environment in which people withdiverse talents and backgrounds can confidently grow andsucceed.• Everyone is valued. We respect employees in each of the skcart reerac

and value their unique contributions. We understand and respect thedifferent roles that each employee plays in the success of Accenture.

• Our diversity is an advantage. Everyone brings distinct experience,talents and background to work. By embracing our differences, wesupport each other better and in turn, serve our clients better.

• We are confident in our skills and optimistic in our work. Throughpersistence and goal-directed activities, we focus not on the obstaclesin our way, but on clear pictures of future accomplishments. A positiveattitude makes success more likely.

2. We help individuals develop specialized skills—encouraging them to take on greater responsibility andenabling them to grow in confidence, competence andmarketplace relevance.• We want people to be their best. We stretch ourselves to grow skills

and deepen abilities, encouraged by our leaders who seek ways tostimulate our growth. We are confident that when we take on a newstretch role, with all its potential for risk and reward, our leaders will bethere to support us.

• We respond positively to criticism. Great critical feedback teaches usand provides the basis for future improvement. We use it as a learningopportunity to do better next time, and to focus on the future.

• We expect our people to actively build market-relevant skills.Accenture seeks people with the right combination of technical,functional and industry skills for client roles. While roles vary in howthey build or use a person’s specialization, our people choose to engageand contribute and not to be idle.

3. We leverage the unique attributes of individuals to createdynamic, innovative teams.• Accenture celebrates intellectual diversity. Creative dynamism comes

from the interplay of good ideas, bad ideas and still-forming ideas—theyall drive innovation.

• We honor ingenuity. We recognize inventive employees who createnew, patentable assets and drive our innovation agenda. Whether itis a new area of business for Accenture, a new software application,or a way we can reengineer one of our own business processes, eachinnovative idea helps us achieve high performance.

• Team members inspire each other. We appreciate how each person’sunique perspective continuously refreshes our teams with enthusiasmand vitality. We encourage people to express their unique perspectivesand expect others to respect them.

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.




4. We reward leadership excellence and we value theleadership contributions of all our people—as peopledevelopers, value creators and business operators.• Our employees balance complex and varied responsibilities.

Developing people, creating value and running a business requirediscipline and a desire to excel. Our leaders master a balancingact, generating profit while creating a strong legacy and achievingsustainable shareholder and stakeholder value.

• Accenture rewards those who master the contribution balancingact. Our performance management process drives compensation,promotion, as well as company equity for top performers.

• We use good judgment. To win we apply the right kind of intelligencein the right context based on our experience and the input of others.

5. We encourage collaboration by fostering trust, sharedgoals and mutual accountability.• We can achieve more by working together. Collaboration brings out

the best in us—it stirs us to reach higher because it forces us to beaccountable for our ideas and work product.

• We work toward the same goals. Success is created throughteaming—assembling the right skills from experts in different fields.Everyone in the team has to feel accountable for achieving the resultsand trusting that others will do the same.

• We rely on people to ask for help when they need it. We expect ourpeople to use their initiative to solve problems, but we want them toreach out whenever they are stuck or fear that something may fail.

6. We invest in our people and their career growthby encouraging continual learning and by creatingopportunities that support near-term developmental needsand long-term career progression.• Accenture invests heavily in our people. While there are times when

people should not leave a project, taking time out from serving clientsto develop market-relevant skills does not hinder individual performanceor success.

• Our people need a portfolio of skills. Accenture believes our peoplemust sharpen not only skills that meet their long-term career goals, butalso skills that tackle urgent marketplace needs, which may include lessappealing kinds of technical expertise.

Q&A for Best People Action Statement #4

Why do we conduct a peer-to-peer rating process at Accenture?Accenture operates as a meritocracy—meaning we recognize and reward employees on the basis of relative contribution. Our relative rating process helps to achieve our goal of rewarding our strongest performers and sends direct and constructive feedback to all employees.


Who can help me manage my career at Accenture?We have a strong culture of developing people. Employees should seek career guidance from career counselors and mentors and are expected to own their career development. They are encouraged to be proactive in planning career goals and taking action to gain the experience and skills needed to achieve career aspirations.




7. Accenture supports our people who choose to volunteertheir time and skills for the benefit of communities and theenvironment.• Our people are passionate volunteers. No matter what their career

level, kcart reerac or country, our people can get involved in manydifferent volunteering activities. By offering our personal expertisebeyond commercial activity, we align our goals with the company’sgoals of being a good corporate citizen.

• Accenture supports employees who donate their time and skills forthe benefit of others.

8. We are responsible for managing our own careers andpursuing our personal definitions of success.• We own our careers. Based on the company’s business needs, our

people pursue their career paths and drive them through their talents,skills and ability to perform. We encourage mentoring, counselingand attentive leadership, and each person is ultimately responsible forseeking out opportunities that meet their goals.

• Individual objectives should line up with both the company’simmediate goals and long-term strategy. Each of us should be able toexplain the business case for any particular task we are working on andprove its value to our shareholders.

9. We do not ask our people to compromise theirpersonal values nor their professional obligations, such asconfidentiality obligations to former employers.• We respect the obligations new people bring. We respect valid and

enforceable obligations that candidates and new employees may haveto former employers, such as confidentiality obligations or agreementsnot to compete or to solicit former clients or colleagues.

• We expect new Accenture people to be aware of these obligationsand to notify their supervisors immediately if a job activity may conflictwith those obligations.


Someone from a competitor just joined Accenture. I’d like to learn about a business process and pricing that her former employer uses. Can I ask?

O .oN btaining competitive information from former or current employees is a delicate matter. Avoid putting yourself and others at risk. Seek information about our competitors from the Accenture Competitor Intelligence group, a team dedicated to obtaining this information in an appropriate manner.



22 | Integrity Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

Integrity

1. We create an inclusive and safe environment—one thatencourages open debate, gives everyone a voice and enablespeople to raise issues without fear of retaliation.• We speak up. No matter what our career level, our collaborative

culture demands that we speak up and listen receptively to other’spoints of view. Raising concerns and solving problems early is good forthe team, for Accenture and for our clients.

• We focus on the message, not the messenger. The power of aperson’s ideas should not be undermined by their accent, languagecapability, mastery of company jargon or our failure to listen.

• We are honest. We are each responsible for creating an environmentthat is safe for others to express concerns honestly and openly, freefrom retaliation.

2. We build trust-based relationships through consistentethical personal conduct and by living our core values.• Trust is earned. The foundations of a trust-based relationship are a

person’s competence, intent and character. We persevere to masterprofessional skills, are honest in our intentions, and authentic in howwe portray our qualities to each other and our clients.

• Our core values guide our actions in all we do. We say openly thatour actions are based on our understanding of right and wrong, evenif that position is unpopular, and we adhere to our Code of BusinessEthics and core values in all circumstances.

• We represent Accenture and always act professionally. Whether atwork, travelling on business, attending training or social events withcolleagues or clients, we are always “ambassadors” of Accenture—withour behavior reflecting on ourselves and Accenture. We are defined, as afirm and as individuals, by the highest standards of ethical, professionaland respectful conduct at all times in work-related situations.

3. We prepare and provide accurate, timely and completereports for our clients and other stakeholders.• As a public company, Accenture must disclose financial and

operational information to the U.S. Securities and ExchangeCommission, local authorities and regulatory bodies.

• Everyone plays a part in accurate disclosure. Accenture’s financialdisclosures rely on accurate business records, client invoices, timeand expense reports, and hours worked. Our experts such as InvestorRelations, Legal, Finance and Corporate Communications are responsiblefor responding to requests for information in their area of expertise,which ensures consistent and appropriate communications.

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.




4. We protect our clients’ and others’ proprietaryinformation and respect their intellectual property rights.• We protect confidential information. Confidential information is any

information or material not generally available to the public that isgenerated, collected or used by Accenture that relates to our business,research and development activities, clients or employees. When wereceive confidential information from a client or others, we make surewe understand our legal obligations and follow them.

• We only use confidential information as permitted. We useconfidential information only for the purpose provided. After thatpurpose has passed, we dispose of copies of the materials, unlessotherwise required by contracts or policies.

• We get permission to share others’ information. We do not review,discuss, disclose, copy or use any copyrighted, licensed or confidentialAccenture, client or third-party information except as authorized, andwithout first making sure we have proper clearance. We are cautiousabout discussing business matters with anyone outside of Accenture,on the Internet or within hearing distance of outsiders (for example,in elevators), including family and friends. If we are unsure if theinformation is confidential, we treat it as such.

• We respect others’ rights. Just because something is downloadablefrom the Internet does not mean it can be freely used. We do notdownload or use copyrighted materials—films, music files, softwareprograms or source code—without a proper license that we understandand follow.

• Only those with a need to know use confidential information. Wemake sure that only authorized people with a need to know have accessto confidential information. Legal helps us understand any limitationsand answers any questions.

5. We avoid actual and perceived conflicts of interest andensure that our personal and financial relationships andactivities do not compromise Accenture’s objectivity orreputation.• Our personal, social and financial activities and interests should not

interfere with our objectivity and our obligation to serve the bestinterests of Accenture pursuant to our core values, Code of BusinessEthics and policies, or compromise Accenture’s objectivity orreputation, including by creating perceived conflicts for Accenture.We don’t allow personal interests, investments, relationships andactivities (including those of family members) to conflict with our workor how we serve our clients.

• Family and personal relationships in the workplace should notundermine a professional work climate. If such relationshipscould interfere with or potentially influence employment, includingperformance evaluations, promotions, career progression or workassignments, or otherwise create a perception in the workplace ofinequity, bias or harassment, we must proactively consult withHuman Resources.

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

• We avoid conflicts of interest, and when a potential conflict doesarise, you must disclose it. Reporting potential concerns is easy, andoften resolvable, but you need to use sound judgment and err on theside of disclosure to your supervisor. If you doubt whether a situationraises a potential conflict, contact the Ethics Group at [email protected], your career counselor, any member ofmanagement, Human Resources or Legal to make sure you are doingthe 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.

Q&A for Integrity Action Statement #5

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

• Does either of you exercise influence over theother at work?

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

• Does either of you provide input on the other’sperformance, 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.



mailto:compliance.program%40accenture.com?subject=Code%20of%20Business%20Ethics

mailto:compliance.program%40accenture.com?subject=Code%20of%20Business%20Ethics







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.

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.


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?









8. We are fierce but fair competitors.• “Competition” or “antitrust” laws are complex and differ by

country. They prohibit agreements or other actions that might unreasonably restrain competition or abuse a strong market position.

• Every interaction with competitors carries risk. Make sure you understand the rules around interacting with competitors because any interaction with a competitor, including teaming arrangements; joint ventures, alliances and other collaborations; information sharing; or roundtable and trade association meetings, may be subject to scrutiny and form the basis for accusations of anticompetitive conduct. Our clients face similar risks, and we must be careful when working with multiple clients in a particular industry or hosting roundtables for our clients in their industry. We must ensure that we are not perceived as helping clients communicate competitively sensitive information to one another or otherwise impermissibly align their conduct.

• Competitors today/partners tomorrow. Given the changing market, Accenture offerings and the overall environment, we find ourselves working with our competitors in various contexts—sometimes as competitors, sometimes as business partners. We must understand the reason for the collaboration before sharing any sensitive information with any collaboration partner, and limit the information we share only for legitimate purposes.

• For additional information see Policy 1322—Antitrust and Competition.

9. We handle “inside information” appropriately and lawfully.• We know what constitutes inside information—“material,”

“nonpublic” information. Inside information generally is not available to the public and could, if publicly known, affect the market price or trading of a company’s securities (stock, for example).

• We do not trade on or disclose inside information. If we possess inside information, we do not buy or sell Accenture’s securities (or the client’s or any third-party’s securities) or provide such information to others, until it officially becomes public. We do not tell others to buy or sell securities or provide “tips,” either in the form of details, such as “our third-quarter earnings next week will be great” or as general comments, based on nonpublic information.

• We know what “material” information is. Information is material if it could affect the price of a security, or if a reasonable investor would likely consider it important in deciding whether to buy or sell securities.

• We know what “nonpublic” information is. Information is nonpublic if it has not been made available officially and effectively to the general public for at least two full trading days.


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.




https://sites.accenture.com/publishing/CodeOfBusinessEthics_CoreValuesInAction/ActionStatements/Pages/I08.aspx


10. We comply and cooperate fully with investigations,ongoing litigation and audits.• We cooperate with investigations and are honest. Whenever we are

involved in company or government investigations (including CorporateInvestigations, Internal Audit or litigation matters), Accenture expectsus to cooperate fully with investigative instructions and to tell thewhole truth.

• We properly preserve relevant information. We never conceal,change or destroy records or data when we know of or anticipate aninvestigation, litigation or audit.

• We protect confidential communications. We keep strictlyconfidential all information communicated to us in the course of aninvestigation, audit or litigation matter.

• We let the professionals investigate and respond only to properpersonnel. We never initiate an investigation ourselves—all requests toconduct internal investigations must be escalated to and authorized byCorporate Investigations, Global Asset Protection or Legal. We work onlywith authorized Legal personnel to respond to litigation or subpoenas orto requests from the government, law enforcement, external auditors orregulatory agencies.

11. We use electronic technology responsibly andprofessionally.• We secure data. We protect the technology and information entrusted

to us by encrypting it when using mobile media devices. We secure ourtechnology devices through security software and configurations. Wedo not install software or modify configurations that compromise ourtechnology’s security.

• We share data only if there is a business requirement. We only shareinformation—through e-mail, postings to social networking sites andgranting access to systems—based on validated business need. We donot access or handle information for which we do not have a businessneed. Also, we do not retain information after the business need haspassed.

• We conduct ourselves professionally. We conduct digital interactionswith professionalism. We do the right thing at all times even if no oneis looking. We use Accenture provided technology for business purposesand limited and appropriate personal use.

12. We are respectful and professional when using socialmedia sites.• Contributing to online communities—including video, blogs, wikis,

podcasts, virtual worlds and social networking—allows us todemonstrate Accenture’s innovative and collaborative nature. Onlinediscourse helps us promote our capabilities, build stronger relationshipsand enhance our reputation. When using these sites:

— Communicate respectfully: Never post content that is abusive,malicious, obscene, threatening or intimidating, or contains ethnic, religious, gender or other derogatory statements in any message or post that relates to Accenture, our business, our clients, our business partners or our people.

— Be factual and provide context: Your personal online communications should be truthful and supported by facts.

— Be transparent and identify yourself and your association with Accenture. Be sure it is clear that you are affiliated with Accenture when commenting on Accenture matters.

— Protect confidentiality and intellectual property: Respect all copyright, trademark, confidential information, and other intellectual property laws. Do not identify a company as an Accenture client unless you have authorization to do so in your social media posts.

— Protect privacy: Always be mindful of your privacy and respect the privacy of others.

— Get permission to speak on behalf of Accenture: Obtain appropriate approvals to provide an official Accenture position about a topic related to Accenture’s business. Refrain from making statements on social media that will be perceived by others as stating an official Accenture position without first obtaining appropriate approvals.

• We are each personally responsible for the content we post online.Our core values guide the way we behave and make decisions, andthese same principles apply to our online activities.

• For more information see Policy 1461—Social Media, Policy 0057—Acceptable Use of Information, Devices, and Technology, Policy 1431—Data Management and Policy 0069—Confidentiality


Can you post on a public social media site a summary of or reference to a new, innovative cloud deployment for an Accenture client to demonstrate Accenture’s leadership in the cloud space?No, you must never disclose Accenture’s or our client’s or other third party’s proprietary or confidential information even if your intentions are in the best interests of our business. Such information belongs to Accenture or others, and its disclosure could cause significant—sometime irreparable—harm to our business, our client’s business, or to the business of other third parties. It could also cause harm to our relationships with our client or other third parties jeopardizing future business, our reputation and our shareholder value. Only authorized official spokespersons for the company are permitted to speak on behalf of Accenture.

You must protect confidential and proprietary information of Accenture, our clients and all third parties with which we do business at all times and only use such information as absolutely necessary and only as permitted by Accenture’s policies and our client contracts. You may re-tweet or otherwise share information only if this information has already been made public by Accenture, for example, through an official tweet or other social media disclosure.









27 | Stewardship Visit the Accenture Business Ethics Line Visit the Code of Business Ethics website

Stewardship

1. We do business in a manner that is socially, economicallyand environmentally responsible.• Stewardship is personal, not just institutional. Every Accenture

employee has a role to play in the stewardship of our business. It is upto each of us to act as a steward to contribute to the long-term successof our company.

• Our influence is global. Accenture has a responsibility to encourageand enable sustainable practices among our employees, clients, suppliersand the charitable and nonprofit organizations we support. Becausewe have operations in more than 50 countries, serving clients whereverthey do business around the world, we hold a unique, powerful andglobal position to bring together diverse stakeholders in the pursuit ofsustainable business practices where possible.

• Accenture expects to thrive for generations. Sustainable businesspractices not only help us meet our public commitments to be a goodcorporate citizen, but also have a positive impact on our bottomline by promoting revenue growth, cost reduction and improved riskmanagement.

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.

Q&A for Stewardship Action Statement #1

How can I act as a steward on my client project?Check out Eco Toolkit—A Guide for Account Teams and look for ways to reduce your project team’s environmental impact—whether that means implementing smart work (for example, reducing the number of times some team members travel to the client site per month) or conserving resources (for example, save paper, share deliverables online).

Does your client share our Skills to Succeed objectives?Collaborate with your client to create a corporate citizenship project that helps others to build skills that will enable them to access economic opportunities (get a job, start a business or grow a business). This could include the volunteer time of Accenture people, or be a joint pro bono project for a nonprofit. See more Skills to Succeed project examples on the Corporate Citizenship portal.



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https://kx.accenture.com/Repositories/ContributionForm.aspx?path=C19/50/38&mode=Read

https://sites.accenture.com/publishing/corporatecitizenship/Environment/Pages/default.aspx


2. We balance the short-term demands of our business withthe long-term needs of the company and make investmentsto enhance shareholder value.• Without clients we have no business. Yet we must sell work that

meets Accenture’s interests as well as our clients’. We take a disciplinedapproach to understanding these interests early and we rely on themthroughout the selling, negotiations and delivery.

• We address client pressures for pricing concessions throughcarefully planned strategies that preserve our profitability. We helpclients heal their businesses without infecting our own business withbad contract terms, dangerous precedent and sub-optimal revenues thatundermine our long-term health.

• We have an “Accenture way to negotiate” to achieve better dealeconomics, improve negotiation and relationship behaviors, and resolvedisputes or litigation to mutual satisfaction.

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

the limits to our individual authority as “business operators.” Whensituations arise that require a more specialized or senior-level review,we are prudent in our decision making and seek counsel.

• We put Accenture’s interests first. We focus on Accenture’s interestsand those of our shareholders above any personal interest in maximizingindividual rewards.

• We spend Accenture’s money as if it were our own. We are vigilantand responsible with resources with an eye to the bottom line. Wespeak up when we see waste.

4. We invest time and resources in preparing our nextgeneration of leaders, while striving to mirror the global anddiverse nature of our marketplace.• We identify our next generation of leaders and prepare them

for their role with targeted development and on-the-job growthopportunities.

• We teach the next generation. We expect each generation to takeownership for passing on knowledge and know-how.

5. We operate the company so that we achieve highperformance generation to generation as well as from yearto year.• You matter when you walk in the door. Stewardship is not just

leaving the company a better place than you find it—it is helping othersunderstand that they own the company too. In all that we do, we carrythe responsibility to be great stewards.

• Generational differences enrich our culture. We aim to capture andunleash each other’s special attributes so that every person passes thebest of their experience on to future generations.

6. We expect Accenture people to put the broader interestsof the entire company ahead of the individual interests of agroup or function.• We understand multiple perspectives. We look beyond ourselves,

our team, our group and our geography to consider the impact of ourdecisions, including Accenture’s bottom line.

• We actively build a rich pipeline of sales opportunities to mitigate“deal fever” or tunnel vision—the pressure to meet individual salestargets.

• We do not negotiate against ourselves. For each opportunity wedevelop a negotiation strategy and present a unified face, backed withrobust internal escalation, approval and relationship strategies.

• Saying no to a client is OK. While we work hard to create solutionsfor clients, we recognize that if they do not meet Accenture’s interestswe have alternatives that include walking away and using our resourcesto serve other clients or engagements.

7. Our leaders communicate and demonstrate a sharedvision and a commitment to strategic priorities—helpingemployees understand how individual roles contribute toour overall success.• Our communications are honest, consistent and clear. Whatever

our career level, each leader translates Accenture’s corporate visioninto terms that individuals can understand and act on. We breathe lifeinto Accenture’s strategic priorities through words and actions that aremeaningful and relevant to each person no matter where they are inthe organization.

• We communicate not just to inform, but to motivate and inspire.We deepen the purpose and meaning of our employees’ work by helpingthem understand how their individual efforts play significant roles inthe company’s success and contribute to the positive outcomes weproduce for our clients.




8. Accenture is a good corporate citizen and encourages theactive involvement of employees in the communities wherewe work and live.• Accenture is committed to sustainability, human rights and

antibribery. We hold global ISO 14001 certification for environmentmanagement systems and we are a signatory to the United NationsGlobal Compact.

• Our employees are our ambassadors. Accenture actively enablesemployees to volunteer their time to benefit others, and we encourageour employees to make personal financial contributions to charitableorganizations.

• Accenture has a corporate giving program that operates largelythrough its foundations. We also contribute directly to localcommunities through corporate cash giving and pro bono services, butemployees may not make contributions on behalf of Accenture andexpect reimbursement.

9. We invest in Accenture’s assets, safeguard Accenture’sproprietary and confidential information, and protect anddefend Accenture’s intellectual property.• We protect intangible assets as vigorously as our physical assets.

Intangible assets—our brand, reputation, intellectual property andconfidential information—are as worthy of protection as our equipmentand computers. We do not jeopardize Accenture’s future by losing ourassets through theft, misuse, carelessness or poor client contracts.

• Intellectual property helps us outperform our competitors. We markall Accenture confidential proposals, documents and other materialsaccording to our guidelines. Because our reputation and financial healthmay suffer if competitors obtain confidential information (such ase-mails, personnel records or financial data), we share such informationonly with people who have a need to know and only after confirming anon-disclosure agreement and other safeguards are in place.

• We develop practical innovations throughout our organizationon internal development projects and on client engagements—andprotecting them via patents underpins our business strategy ofdelivering sustained, differentiated value to our clients. We retain andleverage our ownership in Accenture’s intellectual property rights duringnegotiations with clients, vendors and other parties.

10. 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 politicalactivities or events or use Accenture resources to make cash or othercontributions to political candidates or parties.

• Accenture advises government officials on policies that directlyimpact our business. Accenture takes positions on local and globalpolicies and issues important to our business. However, as a generalmatter, Accenture does not take policy positions on behalf of ourclients.

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

• We research before making personal political contributions. In somegeographies, personal political contributions made by our employeescan have a significant negative impact on the company’s ability tocontract with government entities. Before making personal politicalcontributions, our employees will research the relevant campaigncontribution laws particularly where Accenture is a governmentcontractor, and our U.S. employees must obtain pre-clearance beforea personal political contribution is made to U.S. state or local electedofficials or candidates.

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

Q&A for Stewardship Action Statement #9

What is a harmful disclosure of proprietary or confidential information?• Disclosing an unannounced Accenture client

negotiation can hurt us by giving competitorsan opportunity to interfere, and potentially,time to match our solution. It may also violatenondisclosure obligations to our client.

• Disclosing a proposed executive or organizationalchange can hurt employee morale and can interferewith Accenture’s plans.





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 raiseconcerns when he or she experiences or witness unlawful, fraudulentor unethical conduct. Employees who raise concerns help us ensureAccenture continues to operate as one of the world’s most ethical—andhigh-performing—companies. We recognize that raising an ethicalconcern about someone else’s behavior can be difficult. But we all playa role in protecting what we value …our credibility with clients, ourworking environment, our fellow employees, our strength as a brand,our financial performance and our shareholders. Your role is critical. Ifyou have an ethical concern, you have a right to speak up and we wantyou to speak up.

• Accenture will not tolerate any form of retaliation againstan employee who reports an ethical concern in good faith orparticipates in an investigation of a possible violation of ourCode of Business Ethics. If you have experienced or witnessed suchretaliation, please report it.

• Raise concerns or ask questions through your line management andother trusted advisors. Whenever you have an ethical concern we wantyou to raise it with someone. There are many ways to raise an ethicalconcern, and the most effective way may depend on the nature of yourethical concern. You can always raise an ethical concern with yoursupervisor, career counselor, anyone in Accenture Leadership, or anyonein 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 ethicalconcern, your cooperation may be necessary so that we may adequatelyaddress your concern. While we will always respect your right toreport using the Business Ethics Line anonymously (where permitted),Accenture may require or request additional information in some casesto properly investigate the matter.

• Reach out for guidance if you are approached about an ethicalconcern or violation of law. Speaking up is only part of the process.If you are contacted about an ethical concern or violation of law, nomatter what your level, you must take the concern seriously and takeaction. If someone reports an ethical concern or legal violation toyou, consult with your supervisor, career counselor, any member ofAccenture Leadership, Human Resources or Legal to ensure it is properlyhandled. If someone seeks your guidance regarding an ethical concern,take the time to give them the information they need to make the rightdecision. 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 wayto address the concern. The only wrong thing to do is to do nothing.

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

Your Responsibilities






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 poorperformance evaluation, being denied a promotion, being demoted orterminated, or having to endure a hostile work environment.

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

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

• It can come from a different person than the one was the subjectof the reported allegation, such as a close friend who may be inthe subject’s reporting chain who engages in subtle or exclusionarybehaviors 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.

We respect the privacy of our people. We will use your personal information in accordance with Policy 0090—Data Privacy and data privacy law, which may include, for example, informing relevant people about any raised concern when necessary or appropriate.

Disciplinary and Other Action

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.

How do I contact the Global Ethics Group with questions?

Visit the Ethics & Compliance website or contact the Ethics Group at [email protected].

Accenture’s Responsibilities




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About AccentureAccenture is a global management consulting, technology services and outsourcing company, with more than 323,000 people serving clients in more than 120 countries. Combining unparalleled experience, comprehensive capabilities across all industries and business functions, and extensive research on the world’s most successful companies, Accenture collaborates with clients to help them become high-performance businesses and governments. The company generated net revenues of US$30.0 billion for the fiscal year ended Aug. 31, 2014. Its home page is www.accenture.com

This document makes reference to trademarks that may be owned by others. The use of such trademarks herein is not an assertion of ownership of such trademarks by Accenture and is not intended to represent or imply the existence of an association between Accenture and the lawful owners of such trademarks.

Nothing in this Code constitutes a contract of employment with any Accenture person. Any waiver of the Code for any member of the Executive Leadership Team or board of directors may be made only by the board or a committee of the board, and will be promptly disclosed to shareholders as required by law. Likewise, any amendment to the Code will be disclosed promptly in accordance with any applicable legal or listing requirements.

Copyright © 2015 Accenture All rights reserved.

Accenture, its logo, and High Performance Delivered are trademarks of Accenture.

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Documents

Code of Business Ethics: Our Core Values ni Action