Introduction and Commitment to Ethical Conduct
At Acolad, we empower organizations to be local anywhere by blending human creativity with technology to enable communication in any language. As a trusted partner to our customers, we are committed to service excellence, understanding cultural nuances, and maintaining human connections while adhering to both local and global standards and legislation.
We conduct our business with credibility, integrity, and transparency, and expect our partners and suppliers to uphold the same ethical standards, embracing diversity, inclusion, and equity. Our commitment to fostering diverse businesses extends to supporting the economic prosperity of the communities we serve, recognizing that diversity is integral to our identity.
Our success depends on not only a diverse workforce but also the inclusion of diverse suppliers, which drives innovation, competitive advantage, and strengthens our brand reputation. We are dedicated to maintaining the highest standards of social and environmental responsibility, ethical conduct, and continuous improvement.
Acolad ensures compliance with applicable laws and regulations, maintains transparency in our practices, and protects intellectual property and confidential information. We expect all our employees, partners, and suppliers to embody these values in their actions and decisions, contributing to a culture of excellence and integrity worldwide.
All references to Acolad include all affiliates and subsidiaries within the Acolad group.
Management Accountability and Responsibility
Acolad has designated representatives in its companies who are responsible for ensuring implementation and periodic review of the Management System. All Acolad companies also have Corporate Social Responsibility (CSR) and Sustainability representatives who report directly to executive management and have the responsibility and authority to manage social and environmental compliance across the business. At Acolad, we embrace the values and principles established in the ISO 26000 Guideline and the UN Global Compact (UNGC).
Risk Assessment and Management
All Acolad companies have an established process to identify labor and human rights, health, and safety, environmental, business ethics, and legal compliance risks associated with its operations. This process allows us to determine the relative significance of each identified risk and implement appropriate procedures and controls to control them effectively.
Performance Objectives with Implementation Plans and Measures
Acolad Group has written standards, performance objectives, targets, and implementation plans, including periodic assessments of the performance against those objectives.
Audits and Assessments
Acolad conducts periodic evaluations of its facilities and operations, as well as the facilities and operations of its subcontractors and next-tier suppliers to endure compliance with this Code and the law.
Ethics and Standards of Conduct
Acolad is committed to the highest standards of ethical conduct in all of its endeavors and makes a point of conducting every aspect of its business, including relationships, practices, sourcing, and operations, in the same way.
Business Integrity
Acolad shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage and will abide by all applicable anti-corruption laws and regulations of the countries in which it operates, including the Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption conventions.
Disclosure of Information
Acolad commits to accurately record information regarding its business activities, labor, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties.
Protection of Intellectual Property
Acolad shall respect intellectual property rights, safeguard customer information, and manage technology and know-how in a manner that protects intellectual property rights.
Employment Practices
Acolad is committed to fair employment practices and strives to provide a safe and productive work environment that maximizes individual potential, foster creativity and encourages collaboration and teamwork. We expect our suppliers to uphold the same standards of fairness in their employment practices.
Our selection and hiring processes are conducted with respect, transparency, and adherence to local laws and practices, ensuring no false expectations are created.
We provide equal opportunities, , selecting and recruiting employees based on their ability, knowledge,experience and alignment with our corporate values.
We value diversity and a welcome individuals who bring different perspectives to our team. .
Acolad is dedicated to full compliance with all local legislation and regulations.
Interpersonal Relationships
Acolad is committed to fostering a workplace culture where interpersonal relationships enhance collaboration and teamwork, driving innovation and achieving excellence in everything we do.
Human Rights
As a company that believes in the power of acting with integrity, Acolad seeks to advance respect for human rights.
Every employee of Acolad shall treat one another fairly, with courtesy, respect, and dignity, without verbal or physical abuse, regardless of position or contractual status, gender, sexual orientation, or ethnicity.
Acolad’s commitments to integrity and social responsibility are extended to its worldwide supplier base.
Antidiscrimination
Acolad will not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, or union membership, in hiring and other employment practices. We will also not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety and shall not improperly discriminate based on test results.
Anti-Harassment and Abuse
Acolad commits to maintaining a workplace free of harassment and abuse and will not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.
Prevention of Involuntary Labor and Human Trafficking
Acolad is committed to ensure that all work is voluntary. We do not engage in or tolerate human trafficking or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of person by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.
We will not withhold workers' original government-issued identification and travel documentsWe ensure that all workers' contracts clearly convey the conditions of employment in a language they understand. Acolad will not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.
Acolad will ensure that any third-party recruitment agencies are compliant with the provisions of this Code and applicable laws. Suppliers recruiting foreign contract workers either directly or through third party agencies, shall be responsible for covering all fees and expenses that exceed one month of the worker's anticipated wages.
Prevention of Underage Labor
Acolad shall employ only workers who are at least 18 years of age or the applicable minimum legal age, whichever is higher.
Working Hours and Wages
Compensation paid to workers must comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees should have the ability to earn fair wages, as determined by applicable local law.
Freedom of Association and Collective Bargaining
Acolad complies with applicable laws and regulations governing the legal rights of their employees to join or not to join worker organizations, including trade unions, and the right to collectively bargain, if they choose to be represented.
Health and Safety
Acolad requires that its suppliers take the necessary steps to follow safe work practices and comply with all applicable health and safety guidelines.
Occupational Health, Safety, and Hazard Prevention
Acolad shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. and provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use.
Emergency Preparedness
Acolad shall identify and assess potential emergency situations. For each situation, Acolad will develop and implement emergency plans and response procedures that minimize harm to life, environment and property.
Incident Management
Acolad has a system for workers to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Acolad implements corrective action plans to mitigate risks, provide necessary medical treatment, and support workers in returning to work .
Working and living Conditions
Acolad shall provide workers with accessible, clean toilet facilities and safe drinking water.
Health and Safety Communication
Acolad will provide workers with appropriate workplace health and safety training in their primary language. Health and safety related information shall be clearly posted atevery facility.
Worker Health and Safety Committees
Acolad supports worker health committees to enhance ongoing health and safety education and to encourage worker input on, and participation in, health and safety issues in the workplace.
Environment
Acolad is committed to protecting the environment, and environmental responsibility is at the core of how we operate. Acolad shall develop, implement and maintain environmentally responsible business practices.
Hazardous Substance Management and Restriction
Acolad shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances.
Non-Hazardous Waste Management
Acolad will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous waste.
Pollution Prevention and Resource Reduction
Acolad strives to eliminate or reduce waste of all types, including waste of water and energy. Reductions can be achieved by using various means, such as modifying the production, maintenance, or facility processes, practicing materials substitution and recycling and conserving materials.
Confidentiality
Acolad suppliers with access to confidential information must not disclose such information to other parties without Acolad written consent. Suppliers must treat all information of, or supplied by Acolad, its customers, other suppliers and/or other business partners, which is confidential, proprietary and/or not publicly available as confidential. Such confidential information may include, but is not limited to, the following categories of information: products and services, pricing, costs, customers, employees, operating systems, policies and practices designs, production, quality, communication, technologies and know-how, engineering, technical and scientific. Acolad Confidentiality policy is defined by the “Policy_on_Confidentiality_and_Compliance” document and all the employees, suppliers, and other-tier parties in business relationship with Acolad must observe this policy.
Security
As a high-quality service provider Acolad is committed to earning and keeping the trust of all our stakeholders; and is committed to protecting our own business processes, which rely on our information systems. To achieve these goals, Acolad is committed to:
- Confidentiality – by preserving authorized restrictions on access and disclosure, including means for protecting privacy and proprietary information
- Integrity – by guarding against improper information modification or destruction, including information non-repudiation and authenticity
- Availability – by ensuring timely and reliable access to and use of information.
Anticorruption Measures
Active and passive corruption
The Acolad Group has a zero-tolerance policy towards acts of corruption. Such behavior is illegal and can lead to severe consequences for all parties involved, including jail for individuals and financial penalties for the Company.
We are committed to conducting our business with transparency and integrity and will therefore ensure that all our transactions and those of our suppliers comply with anti-corruption laws (such as the French Loi Sapin II, the US FCPA as well as the UK Bribery Act 2010).
An act of corruption may be defined as the act of offering, promising to offer, solicitating or accepting, directly or indirectly, financial or any other advantage(s), for the purpose of improperly influencing a business decision. Corruption can be active or passive.
Article 1 of Loi Sapin II lists the criminal acts as corruption, influence peddling, bribery, illegal taking of interest, embezzlement or misappropriation of public property and favoritism.
Bribery, favoritism, illegal taking of interest, embezzlement, or misappropriation of public property are infringements that can only be committed by public officials. However, individuals and companies can be convicted of complicity, concealment or laundering of these offences.
Influence peddling
Influence peddling is the fact of consenting or proposing, soliciting or agreeing, without right, at any time, directly or indirectly, to offers, promises, gifts, presents or advantages of any kind to a person, for himself or for another, in order to abuse or because he has abused his real or supposed influence with a view to obtaining from a public authority or administration distinctions, employment, contracts or any other favorable decision.
A whistleblowing platform and reporting mechanisms are available to any employee facing or witnessing this type of situation.
Conflicts of Interest
Acolad conducts business in a professional, honest, ethical, and transparent manner. And excepts the same from its suppliers. Suppliers must not engage in any activity that creates an actual or perceived conflict of interest. t. A conflict of interest refers to any situation of interference between a public interest and public or private interests which is likely to influence or appear to influence the independent, impartial and objective exercise of a function.
Entertainment, gifts, and payments
Providing or receiving gifts, money, goods or services for personal use, personal discounts, loans, gifts of non-business-related travel or accommodations, personal favors or any other benefit which might influence or raise doubts as to the impartiality of the recipient or damage the reputation of Acolad for fair dealing are strictly prohibited.
While offering or receiving gifts and invitations can be seen as gestures of goodwill in business relationships, they must never be given or accepted with the intent to influence business decisions or relationships. If gifts or invitations may affect a decision-making process or be perceived as an attempt to gain an undue advantage, this could be considered an act of corruption, and individuals or companies involved may face legal consequences.
It is essential that every employee of Acolad ensures they have the authority to offer any gift or invitation and that the recipient is permitted to accept it.
Illegal payments/Facilitation payments
Offering or accepting bribes, kickbacks or improper payments of any kind is strictly prohibited, without exception, in all circumstances. Facilitation payments involve directly or indirectly paying an undue amount to a public official to expedite administrative formalities, which should be obtained through normal legal channels. Such payments are prohibited by French law and are considered to be acts of corruption.
Acolad prohibits all illegal payments, and each payment shall be recorded in the company’s books.
Sponsorship and patronage
A “sponsorship" is a kind of advertising operation, whereby a "sponsor" participates in the financing or material support of a project or initiative in exchange for various forms of visibility. Most of the time, this consists in adding the sponsor’s brand name and logos on the advertising materials of the initiative/project.
A “patronage” refers to any financial or material support (e.g. services offered) given to an initiative, a work or a project. This type of operation differs from sponsorship by the fact that no direct consideration is received by the company providing the support.
Insider dealing
As a group serving clients in the financial sector or issuing shares, Acolad is committed to complying with all applicable laws and regulations to prevent insider dealings.
Any Acolad employee with access to confidential information, which has not been made public yet, and relates, directly or indirectly, to a company or organization issuing financial instruments (e.g. shares and debts), and which, if made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments (= inside information) should be aware that trading or dealing in financial instruments, such as stocks and securities, based on inside information is illegal. Adittionally, disclosing inside information to others, is also a criminal offence.
Customers
Acolad does not discriminate against customers or markets for any reason other than to comply with legal provisions. Unlawful discrimination is a violation of our Code and global competition laws and will not be tolerated. If you witness or suspect unlawful customer or market discrimination report the behavior immediately to Anonymous line or the Legal & Compliance.
We commit to treating customers with integrity and professionalism and always avoid arrogance. To build and maintain customer relationships based on trust and credibility, we only make commitments that are commensurate with our abilities. If unforeseen circumstances make it impossible to meet a commitment, the person involved must inform his/her immediate supervisor, as well as the customer.
Our sales activities will be free of false representations regarding product quality and/or availability, delivery dates and payment terms. We must market our products and services honestly and accurately. Using deceitful or dishonest practices is a violation of our Code and our corporate values and will not be tolerated.
Community
As a responsible member of the global community, we are engaged in participating directly or indirectly with organizations or programs designed to promote integration, development, and improved quality of life worldwide. Our participation may include counsel, management, sponsorships, or any other support involving our products, assets and/or services.
Government
Acolad advocates a policy of awareness and compliance with, laws, regulations, standards and other legal provisions in every country in which we operate.
No-one at Acolad may commit an illegal or unethical act, or instruct others to do so, for any reason.
Documentation and Records
Acolad has processes to identify, understand, and implement applicable laws and regulations and requirements of this Code and maintains documents and records to ensure regulatory compliance.
Training and Communication
Acolad develops and maintains management and worker training programs to ensure proper implementation of its policies and procedures and to fulfill improvement objectives.
Processes are in place to communicate clear and accurate information about our performance, practices, policies, and expectations to our workers, next-tier supplier(s), and customers.
Acolad also has an ongoing process to obtain feedback on its practices related to this Code to foster continuous improvement.
Corrective Action Process
Acolad has a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.
Sanction:
Non-compliance with the rules engages the personal responsibility of the employee and exposes him/her to penalties, particularly criminal penalties, according to the applicable legislation.
Acolad undertakes to:
- Take all reports into account
- Investigate reports with diligence
- Evaluate the facts objectively and impartially
- Take appropriate measures and disciplinary action.
Under French law, bribery and influence peddling are punishable by a fine of between €500,000 and €1,000,000 and imprisonment of between 5 and 10 years for individuals. Companies risk a fine of between €2,500,000 and €5,000,000.
It is the responsibility of everyone to implement this Code of Conduct.
Speaking Up
This Code of Conduct is based on our values and provides guidance to our employees and partners on how to conduct themselves in various situations. We are committed to fostering a culture of transparency and integrity, clearly defining who we are and what we stand for to our clients, stakeholders, and the broader society.
Acolad encourages all stakeholders to report any suspected violation of the principles stated in this Code of Conduct.
Something doesn’t seem right? Facing a dilemma? Have a question that leads to more difficult questions? Need advice?
Everyone, no matter what our level or role, is empowered to speak up when dealing with behavior or facing a situation that doesn’t seem right. We all have a responsibility to report and express our concerns, and to do so fairly, honestly, and professionally.
Any reported concerns will be handled with appropriate confidentiality and discussed with others only as needed or advisable under the circumstances.
Speaking up is an essential first step. Acolad thoroughly investigates all allegations, complaints, or concerns and takes appropriate action to address them.
Acolad does not tolerate retaliation of any kind against anyone who shares a good-faith concern or participates in an investigation.
As much as we encourage honest reporting, we do not tolerate knowingly false reports as these actions can also constitute a violation.
Introduction and Commitment to Ethical Conduct
At Acolad, we empower organizations to be local anywhere by blending human creativity with technology to enable communication in any language. As a trusted partner to our customers, we are committed to service excellence, understanding cultural nuances, and maintaining human connections while adhering to both local and global standards and legislation.
We conduct our business with credibility, integrity, and transparency, and expect our partners and suppliers to uphold the same ethical standards, embracing diversity, inclusion, and equity. Our commitment to fostering diverse businesses extends to supporting the economic prosperity of the communities we serve, recognizing that diversity is integral to our identity.
Our success depends on not only a diverse workforce but also the inclusion of diverse suppliers, which drives innovation, competitive advantage, and strengthens our brand reputation. We are dedicated to maintaining the highest standards of social and environmental responsibility, ethical conduct, and continuous improvement.
Acolad ensures compliance with applicable laws and regulations, maintains transparency in our practices, and protects intellectual property and confidential information. We expect all our employees, partners, and suppliers to embody these values in their actions and decisions, contributing to a culture of excellence and integrity worldwide.
All references to Acolad include all affiliates and subsidiaries within the Acolad group.
Management Accountability and Responsibility
Acolad has designated representatives in its companies who are responsible for ensuring implementation and periodic review of the Management System. All Acolad companies also have Corporate Social Responsibility (CSR) and Sustainability representatives who report directly to executive management and have the responsibility and authority to manage social and environmental compliance across the business. At Acolad, we embrace the values and principles established in the ISO 26000 Guideline and the UN Global Compact (UNGC).
Risk Assessment and Management
All Acolad companies have an established process to identify labor and human rights, health, and safety, environmental, business ethics, and legal compliance risks associated with its operations. This process allows us to determine the relative significance of each identified risk and implement appropriate procedures and controls to control them effectively.
Performance Objectives with Implementation Plans and Measures
Acolad Group has written standards, performance objectives, targets, and implementation plans, including periodic assessments of the performance against those objectives.
Audits and Assessments
Acolad conducts periodic evaluations of its facilities and operations, as well as the facilities and operations of its subcontractors and next-tier suppliers to endure compliance with this Code and the law.
Ethics and Standards of Conduct
Acolad is committed to the highest standards of ethical conduct in all of its endeavors and makes a point of conducting every aspect of its business, including relationships, practices, sourcing, and operations, in the same way.
Business Integrity
Acolad shall not engage in corruption, extortion, embezzlement, or bribery to obtain an unfair or improper advantage and will abide by all applicable anti-corruption laws and regulations of the countries in which it operates, including the Foreign Corrupt Practices Act (FCPA) and applicable international anti-corruption conventions.
Disclosure of Information
Acolad commits to accurately record information regarding its business activities, labor, health and safety, and environmental practices and shall disclose such information, without falsification or misrepresentation, to all appropriate parties.
Protection of Intellectual Property
Acolad shall respect intellectual property rights, safeguard customer information, and manage technology and know-how in a manner that protects intellectual property rights.
Employment Practices
Acolad is committed to fair employment practices and strives to provide a safe and productive work environment that maximizes individual potential, foster creativity and encourages collaboration and teamwork. We expect our suppliers to uphold the same standards of fairness in their employment practices.
Our selection and hiring processes are conducted with respect, transparency, and adherence to local laws and practices, ensuring no false expectations are created.
We provide equal opportunities, , selecting and recruiting employees based on their ability, knowledge,experience and alignment with our corporate values.
We value diversity and a welcome individuals who bring different perspectives to our team. .
Acolad is dedicated to full compliance with all local legislation and regulations.
Interpersonal Relationships
Acolad is committed to fostering a workplace culture where interpersonal relationships enhance collaboration and teamwork, driving innovation and achieving excellence in everything we do.
Human Rights
As a company that believes in the power of acting with integrity, Acolad seeks to advance respect for human rights.
Every employee of Acolad shall treat one another fairly, with courtesy, respect, and dignity, without verbal or physical abuse, regardless of position or contractual status, gender, sexual orientation, or ethnicity.
Acolad’s commitments to integrity and social responsibility are extended to its worldwide supplier base.
Antidiscrimination
Acolad will not discriminate against any worker based on age, disability, ethnicity, gender, marital status, national origin, political affiliation, race, religion, sexual orientation, or union membership, in hiring and other employment practices. We will also not require pregnancy or medical tests, except where required by applicable laws or regulations or prudent for workplace safety and shall not improperly discriminate based on test results.
Anti-Harassment and Abuse
Acolad commits to maintaining a workplace free of harassment and abuse and will not threaten workers with, or subject them to, harsh or inhumane treatment, including but not limited to verbal abuse and harassment, psychological harassment, mental and physical coercion, and sexual harassment.
Prevention of Involuntary Labor and Human Trafficking
Acolad is committed to ensure that all work is voluntary. We do not engage in or tolerate human trafficking or use any form of slave, forced, bonded, indentured, or prison labor. Involuntary labor includes the transportation, harboring, recruitment, transfer, receipt, or employment of person by means of threat, force, coercion, abduction, fraud, or payments to any person having control over another person for the purpose of exploitation.
We will not withhold workers' original government-issued identification and travel documentsWe ensure that all workers' contracts clearly convey the conditions of employment in a language they understand. Acolad will not impose unreasonable restrictions on movement within the workplace or upon entering or exiting company-provided facilities.
Acolad will ensure that any third-party recruitment agencies are compliant with the provisions of this Code and applicable laws. Suppliers recruiting foreign contract workers either directly or through third party agencies, shall be responsible for covering all fees and expenses that exceed one month of the worker's anticipated wages.
Prevention of Underage Labor
Acolad shall employ only workers who are at least 18 years of age or the applicable minimum legal age, whichever is higher.
Working Hours and Wages
Compensation paid to workers must comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. Employees should have the ability to earn fair wages, as determined by applicable local law.
Freedom of Association and Collective Bargaining
Acolad complies with applicable laws and regulations governing the legal rights of their employees to join or not to join worker organizations, including trade unions, and the right to collectively bargain, if they choose to be represented.
Health and Safety
Acolad requires that its suppliers take the necessary steps to follow safe work practices and comply with all applicable health and safety guidelines.
Occupational Health, Safety, and Hazard Prevention
Acolad shall identify, evaluate, and manage occupational health and safety hazards through a prioritized process of hazard elimination, engineering controls, and/or administrative controls. and provide workers with job-related, appropriately maintained personal protective equipment and instruction on its proper use.
Emergency Preparedness
Acolad shall identify and assess potential emergency situations. For each situation, Acolad will develop and implement emergency plans and response procedures that minimize harm to life, environment and property.
Incident Management
Acolad has a system for workers to report health and safety incidents and near-misses, as well as a system to investigate, track, and manage such reports. Acolad implements corrective action plans to mitigate risks, provide necessary medical treatment, and support workers in returning to work .
Working and living Conditions
Acolad shall provide workers with accessible, clean toilet facilities and safe drinking water.
Health and Safety Communication
Acolad will provide workers with appropriate workplace health and safety training in their primary language. Health and safety related information shall be clearly posted atevery facility.
Worker Health and Safety Committees
Acolad supports worker health committees to enhance ongoing health and safety education and to encourage worker input on, and participation in, health and safety issues in the workplace.
Environment
Acolad is committed to protecting the environment, and environmental responsibility is at the core of how we operate. Acolad shall develop, implement and maintain environmentally responsible business practices.
Hazardous Substance Management and Restriction
Acolad shall implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle hazardous substances.
Non-Hazardous Waste Management
Acolad will implement a systematic approach to identify, manage, reduce, and responsibly dispose of or recycle non-hazardous waste.
Pollution Prevention and Resource Reduction
Acolad strives to eliminate or reduce waste of all types, including waste of water and energy. Reductions can be achieved by using various means, such as modifying the production, maintenance, or facility processes, practicing materials substitution and recycling and conserving materials.
Confidentiality
Acolad suppliers with access to confidential information must not disclose such information to other parties without Acolad written consent. Suppliers must treat all information of, or supplied by Acolad, its customers, other suppliers and/or other business partners, which is confidential, proprietary and/or not publicly available as confidential. Such confidential information may include, but is not limited to, the following categories of information: products and services, pricing, costs, customers, employees, operating systems, policies and practices designs, production, quality, communication, technologies and know-how, engineering, technical and scientific. Acolad Confidentiality policy is defined by the “Policy_on_Confidentiality_and_Compliance” document and all the employees, suppliers, and other-tier parties in business relationship with Acolad must observe this policy.
Security
As a high-quality service provider Acolad is committed to earning and keeping the trust of all our stakeholders; and is committed to protecting our own business processes, which rely on our information systems. To achieve these goals, Acolad is committed to:
- Confidentiality – by preserving authorized restrictions on access and disclosure, including means for protecting privacy and proprietary information
- Integrity – by guarding against improper information modification or destruction, including information non-repudiation and authenticity
- Availability – by ensuring timely and reliable access to and use of information.
Anticorruption Measures
Active and passive corruption
The Acolad Group has a zero-tolerance policy towards acts of corruption. Such behavior is illegal and can lead to severe consequences for all parties involved, including jail for individuals and financial penalties for the Company.
We are committed to conducting our business with transparency and integrity and will therefore ensure that all our transactions and those of our suppliers comply with anti-corruption laws (such as the French Loi Sapin II, the US FCPA as well as the UK Bribery Act 2010).
An act of corruption may be defined as the act of offering, promising to offer, solicitating or accepting, directly or indirectly, financial or any other advantage(s), for the purpose of improperly influencing a business decision. Corruption can be active or passive.
Article 1 of Loi Sapin II lists the criminal acts as corruption, influence peddling, bribery, illegal taking of interest, embezzlement or misappropriation of public property and favoritism.
Bribery, favoritism, illegal taking of interest, embezzlement, or misappropriation of public property are infringements that can only be committed by public officials. However, individuals and companies can be convicted of complicity, concealment or laundering of these offences.
Influence peddling
Influence peddling is the fact of consenting or proposing, soliciting or agreeing, without right, at any time, directly or indirectly, to offers, promises, gifts, presents or advantages of any kind to a person, for himself or for another, in order to abuse or because he has abused his real or supposed influence with a view to obtaining from a public authority or administration distinctions, employment, contracts or any other favorable decision.
A whistleblowing platform and reporting mechanisms are available to any employee facing or witnessing this type of situation.
Conflicts of Interest
Acolad conducts business in a professional, honest, ethical, and transparent manner. And excepts the same from its suppliers. Suppliers must not engage in any activity that creates an actual or perceived conflict of interest. t. A conflict of interest refers to any situation of interference between a public interest and public or private interests which is likely to influence or appear to influence the independent, impartial and objective exercise of a function.
Entertainment, gifts, and payments
Providing or receiving gifts, money, goods or services for personal use, personal discounts, loans, gifts of non-business-related travel or accommodations, personal favors or any other benefit which might influence or raise doubts as to the impartiality of the recipient or damage the reputation of Acolad for fair dealing are strictly prohibited.
While offering or receiving gifts and invitations can be seen as gestures of goodwill in business relationships, they must never be given or accepted with the intent to influence business decisions or relationships. If gifts or invitations may affect a decision-making process or be perceived as an attempt to gain an undue advantage, this could be considered an act of corruption, and individuals or companies involved may face legal consequences.
It is essential that every employee of Acolad ensures they have the authority to offer any gift or invitation and that the recipient is permitted to accept it.
Illegal payments/Facilitation payments
Offering or accepting bribes, kickbacks or improper payments of any kind is strictly prohibited, without exception, in all circumstances. Facilitation payments involve directly or indirectly paying an undue amount to a public official to expedite administrative formalities, which should be obtained through normal legal channels. Such payments are prohibited by French law and are considered to be acts of corruption.
Acolad prohibits all illegal payments, and each payment shall be recorded in the company’s books.
Sponsorship and patronage
A “sponsorship" is a kind of advertising operation, whereby a "sponsor" participates in the financing or material support of a project or initiative in exchange for various forms of visibility. Most of the time, this consists in adding the sponsor’s brand name and logos on the advertising materials of the initiative/project.
A “patronage” refers to any financial or material support (e.g. services offered) given to an initiative, a work or a project. This type of operation differs from sponsorship by the fact that no direct consideration is received by the company providing the support.
Insider dealing
As a group serving clients in the financial sector or issuing shares, Acolad is committed to complying with all applicable laws and regulations to prevent insider dealings.
Any Acolad employee with access to confidential information, which has not been made public yet, and relates, directly or indirectly, to a company or organization issuing financial instruments (e.g. shares and debts), and which, if made public, would be likely to have a significant effect on the prices of those financial instruments or on the price of related derivative financial instruments (= inside information) should be aware that trading or dealing in financial instruments, such as stocks and securities, based on inside information is illegal. Adittionally, disclosing inside information to others, is also a criminal offence.
Customers
Acolad does not discriminate against customers or markets for any reason other than to comply with legal provisions. Unlawful discrimination is a violation of our Code and global competition laws and will not be tolerated. If you witness or suspect unlawful customer or market discrimination report the behavior immediately to Anonymous line or the Legal & Compliance.
We commit to treating customers with integrity and professionalism and always avoid arrogance. To build and maintain customer relationships based on trust and credibility, we only make commitments that are commensurate with our abilities. If unforeseen circumstances make it impossible to meet a commitment, the person involved must inform his/her immediate supervisor, as well as the customer.
Our sales activities will be free of false representations regarding product quality and/or availability, delivery dates and payment terms. We must market our products and services honestly and accurately. Using deceitful or dishonest practices is a violation of our Code and our corporate values and will not be tolerated.
Community
As a responsible member of the global community, we are engaged in participating directly or indirectly with organizations or programs designed to promote integration, development, and improved quality of life worldwide. Our participation may include counsel, management, sponsorships, or any other support involving our products, assets and/or services.
Government
Acolad advocates a policy of awareness and compliance with, laws, regulations, standards and other legal provisions in every country in which we operate.
No-one at Acolad may commit an illegal or unethical act, or instruct others to do so, for any reason.
Documentation and Records
Acolad has processes to identify, understand, and implement applicable laws and regulations and requirements of this Code and maintains documents and records to ensure regulatory compliance.
Training and Communication
Acolad develops and maintains management and worker training programs to ensure proper implementation of its policies and procedures and to fulfill improvement objectives.
Processes are in place to communicate clear and accurate information about our performance, practices, policies, and expectations to our workers, next-tier supplier(s), and customers.
Acolad also has an ongoing process to obtain feedback on its practices related to this Code to foster continuous improvement.
Corrective Action Process
Acolad has a process for timely correction of any deficiencies or violations identified by an internal or external audit, assessment, inspection, investigation, or review.
Sanction:
Non-compliance with the rules engages the personal responsibility of the employee and exposes him/her to penalties, particularly criminal penalties, according to the applicable legislation.
Acolad undertakes to:
- Take all reports into account
- Investigate reports with diligence
- Evaluate the facts objectively and impartially
- Take appropriate measures and disciplinary action.
Under French law, bribery and influence peddling are punishable by a fine of between €500,000 and €1,000,000 and imprisonment of between 5 and 10 years for individuals. Companies risk a fine of between €2,500,000 and €5,000,000.
It is the responsibility of everyone to implement this Code of Conduct.
Speaking Up
This Code of Conduct is based on our values and provides guidance to our employees and partners on how to conduct themselves in various situations. We are committed to fostering a culture of transparency and integrity, clearly defining who we are and what we stand for to our clients, stakeholders, and the broader society.
Acolad encourages all stakeholders to report any suspected violation of the principles stated in this Code of Conduct.
Something doesn’t seem right? Facing a dilemma? Have a question that leads to more difficult questions? Need advice?
Everyone, no matter what our level or role, is empowered to speak up when dealing with behavior or facing a situation that doesn’t seem right. We all have a responsibility to report and express our concerns, and to do so fairly, honestly, and professionally.
Any reported concerns will be handled with appropriate confidentiality and discussed with others only as needed or advisable under the circumstances.
Speaking up is an essential first step. Acolad thoroughly investigates all allegations, complaints, or concerns and takes appropriate action to address them.
Acolad does not tolerate retaliation of any kind against anyone who shares a good-faith concern or participates in an investigation.
As much as we encourage honest reporting, we do not tolerate knowingly false reports as these actions can also constitute a violation.