Accenture PLC

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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