Accenture’s Code of Business Ethics

 Patrick Rowe- Accenture’s Deputy General Counsel

 Jennifer Handa (Associate General Counsel, Global Compliance and Ethics
 Paul Steinke (Director of Ethics Programs)

company’s Code of Business Ethics—a printed statement reflecting the company’s values and
expectations for employees’ conduct—had not kept pace.

having an interest in how the code was framed, Rowe, Handa and Steinke realized that any
changes to the code would require considerable effort- started working on farming new
code of but lots of question came in front of them.
Steinke described his feeling about Accenture’s code when they sat down in the spring of
2016
The code of business ethics was organized around Accenture’s six core values:
 Client Value Creation
 One Global Network
 Respect for the Individual
 Best People
 Integrity
 Stewardship

At the time it was done , it was good piece of work

Example- something like gifts and entertainment you had to think, does that fall under
Integrity, does that fall under One Global Network

Steinke had additional concerns about comingling “individual behaviors with

accountability” and “organizational commitments” in the same document.

As Rowe, Handa and Steinke built the business case for changing the code—that they
would ultimately need to present to Accenture’s CEO, General Counsel, and Chief
Compliance Officer—they examined what other companies were doing.

Portion of Microsoft’s Standard of Business Conduct= difficult decision/situation follow

these steps- Pause, Think & Ask

Steinke- looking at other codes how they organized- kept customers as primary audience
while other directed at multiple audience/ (for example: ’our commitment to our
people,’ ’our commitment to our customers,’ ’our commitment to our shareholders’)- They
dint think as they trying to talk first and foremost to our people.

Rowe, Handa, and Steinke identified three critical attributes-

1) primary purpose should be to serve as a practical guide for employees, while
also serving as a public commitment for external stakeholders including clients,
investors, vendors, and regulators.
2) code should be organized by more intuitive topics to help employees find
answers more easily. Ideally, the code would support day-to-day decision making in
moments that matter and, if necessary, also help employees locate relevant
policies and procedures.
3) improve the employee experience when interacting with the code. In thinking about
the presentation, they wanted to strike the appropriate balance between including
everything needed for the organization to operate effectively, and highly customized
information for employees specific to each person’s role and career level.

Revised Decision-Making Framework- unsure about any conduct or decision/ Ask the
following question-
1.Obligations under the law
2.Obligations to Accenture
3.Obligations to others
4.Do no harm
(if any any answer if YES – DON’T DO IT)
And ask a supervisor/career counselor/any leader @ Accenture/HR/ Legal/ USE THE
Business Ethics Helpline

Rowe, handa & Steinke – developed budget/team subject matter experts/ project plan
and came up with a list of goal on over next 18 months-
–improve and focus content around new compliance processes
–include separate, prominent section on raising concerns
–focused on individual, rather than organizational, commitments
–organize code of business ethics by topic
–shorten code; ideally present code in less than 20 pages
–include table of contents, glossary, and index
–add search functionality
–update graphics and presentation
–add analytic capabilities to understand what individuals are reading within code

wanted it to be more interactive, user-friendly, searchable, and to have the ability to

raise a concern or access a tool directly from the code as opposed to having to leave it to
search for something else and then carry on
challenge to work it out- when presented to top ceo/cco- they asked to make it more
than just good-to devote time and resources

lot of the time was spent with Fjord and Marketing & Communications leadership
thinking about the different potential users and envisioning- most ambitious idea for the
revised code: COBE, Accenture’s Code of Business Ethics chatbot

As Rowe summed it up, “We put our people at the center of the design process and
asked ourselves, how could we inspire and empower them to make good choices and
responsible decisions?

opportunity for a chatbot-employees with quick access, including mobile access, to

answers in critical decision-making moments

came with challenges- lots

Fjord team - chatbot quickly recommended limiting its focus

We decided to focus on topics within the code

they started with their newly revamped code

You will never get a yes or no out of the chatbot,” Handasaid. “Instead, you are going to
get a ‘here’s what I found about X, Y, or Z.’

The revised code launched in the fall of 2017. At its core, Accenture’s Code of Business
Ethics was focused around six behaviors:
1) Make Your Conduct Count
2) Comply with Laws
3) Deliver for Our Clients
4) Protect People, Information and Our Business
5) Run Our Business Responsibly
6) Be a Good Corporate Citizen

“comply with laws” included subsections on anticorruption, anti-money laundering,

competing fairly, data privacy, government compliance, trade compliance, and
insider trading

COBE chatbot was successful for the company – 455 queries per day on average – over
100000 total in 1st year – 90% of time correct answer-Accenture employees at all levels
around the world