GOVERNANCE

COMPLIANCE MANAGEMENT SYSTEM | ACCOLADE

Accolade believes that an effective compliance management system protects the interests of stakeholders, including shareholders, bondholders, creditors, tenants and employees. We strive for excellence and transparency in governance controls, corporate reporting and internal procedures. We are convinced that these factors support a corporate culture that balances entrepreneurial spirit with risk identification, control and prevention.

Accolade continuously reviews and implements industry best practices with regard to governance and compliance, and has adapted its internal procedures to meet international standards.

Accolade operates in full conformity with compliance legislation and applicable EU laws and regulations in all jurisdictions in which it operates. Accolade has adopted a comprehensive Code of Conduct, together with updated policies relating in particular to anti-corruption and anti-bribery, anti-money laundering, data protection, whistleblowing, sustainability and corporate social responsibility (CSR), human rights and human capital, non-discrimination and diversity, political involvement, and relationships with business partners. In order to fulfil these principles, Accolade requires its business partners to comply with these rules, which Accolade considers essential.

Our Code of Conduct is available here.

Our Business Partners Code of Conduct is available here.

Anti-Bribery and Anti-Corruption Policy

Accolade’s Anti-Corruption and Anti-Bribery Policy complies with legal requirements as well as ethical standards, safeguarding both the material and moral integrity of the company. Accolade makes it clear to its clients, suppliers and employees that corruption or any other form of unethical conduct is not and will not be tolerated.

Employees must not, either directly or indirectly, engage in any transactions that could lead to a conflict of interest. They are required to reject any interference, pressure or influence that could compromise impartial decision-making in matters concerning customers or third parties.

Employees may neither accept from nor offer to third parties any gifts or hospitality unless such conduct is reasonable, proportionate, appropriate to the circumstances and in line with internal rules.

Our Anti-Bribery and Anti-Corruption Policy is available here.

Whistleblowing

Accolade encourages its employees and others to report suspected illegal or inappropriate behaviour or matters that are contrary to Accolade’s principles and values.

Accolade has established an ethics line and implemented processes for handling whistleblower reports. The ethics line ensures a high level of protection for whistleblowers, as well as systematic investigation and timely response to reports in accordance with local legislation.

Our whistleblowing page is available here.

Anti-Money Laundering

Accolade strictly complies with all legal regulations concerning the prevention of money laundering. Accolade adheres to all applicable legal and regulatory provisions on anti-money laundering in every jurisdiction where it operates.

Data protection and Privacy

Accolade places great emphasis on complying with principles and regulations for the protection of individuals in connection with the processing of their personal data. Accolade provides individuals whose personal data it collects and processes with information about how their data are handled for specified purposes.

Our Data protection and Privacy Policy is available here.

Sustainability and Corporate Social Responsibility (CSR)

Accolade complies with sustainability and corporate social responsibility (CSR) legislation in all jurisdictions in which it operates. Accolade is committed to the highest standards of environmental protection and strives to ensure that its activities have a positive social impact.

Human Rights

Accolade is committed to protecting human rights and complies with all fundamental human rights principles set out in international charters and conventions and in the Charter of Fundamental Rights and Freedoms. Accolade combats all forms of forced labour, child labour and human trafficking, while respecting the privacy and freedom of expression of its employees. Accolade strictly complies with the requirements for working conditions and health and safety established by law.

Our Anti-Discrimination and Anti-Slavery Policy is available here.

Accolade values freedom, justice and respect. Accolade promotes diversity, equality, inclusion and professional development for employees within the company. Accolade supports the right of every employee to freely associate, join or form organizations without fear of retaliation or discrimination, as part of the company’s commitment to an open and equitable workplace. Accolade also respects the right of individuals to participate in political activities, while remaining politically neutral as a company. Personal political views have no place in Accolade’s business decisions or professional environment.

Our Political Involvement and Freedom of Association Policy is available here.