Integrity

Everything we do is governed by the highest standards of integrity. This means reliability, honesty, openness and respect, and these values apply equally to our work, our customers, our suppliers, our business partners and our colleagues, wherever we operate.

Highest standards

“Behaving in a fair, honest, and respectful way is critical for our business, forming the foundation of our relationship with all stakeholders. We are committed to acting with the highest standards of integrity while always striving to do better, with robust systems and processes in place to embed our core values throughout the business.”

Daniel Bischofberger, CEO Accelleron

We have implemented an Integrity Program with a comprehensive system of measures to ensure we always operate in full accordance with all applicable laws and regulations, and in line with leading international standards and our Code of Conduct.
The Accelleron Integrity Program is based on three key principles: Prevent, Detect and Respond.

Prevent

This is our commitment to creating the right culture, to help prevent any wrongdoing before it happens. It is captured in our Code of Conduct, policies, processes and guidelines, and includes comprehensive training and effective communication with all employees.

Detect

We take a zero-tolerance approach towards ethics and compliance breaches and the processes to detect these issues. This includes providing employees and stakeholders with the channels to report concerns, such as the Accelleron SpeakUp reporting site.

Respond

This is taking action over any wrongdoing, by investigating any issues to recognize and resolve misconduct matters and implement improvements. The key objective is to prevent any recurrence, and we commit to provide clear answers and discipline improper behaviour as necessary. We apply an ethical model supported by individual accountability and personal ownership of our business principles.

Code of Conduct

Our Code of Conduct is one of the key elements of the integrity program, containing our collective and individual commitment to integrity.

It is binding on everyone at Accelleron and who does business with us, serving as a practical guide for our workforce, our suppliers and our business partners in how we operate worldwide. In the Code of Conduct you will find concrete support on how to implement our values and standards in practice.

We have a strict zero-tolerance policy towards any illegal behaviour or breaches of our Code of Conduct, and take appropriate disciplinary action as a result.
The Code of Conduct also sets out how employees, contractors and stakeholders can report any concerns of wrongdoing.

Integrity

Our Integrity program covers 4 key areas: anti-corruption, trade compliance, data protection and antitrust.

Integrity program

Anti-corruption

We are committed to acting with the highest standards of integrity, conducting all of our business in an honest, fair and ethical manner. We strictly prohibit bribery or corruption, whether direct or indirect, and have a zero-tolerance policy in place. Our Global Anti-Corruption Policy provides guidelines on: gifts, travel and hospitality, facilitation payments, political contributions, sponsorship and donations, conflicts of interest and third party management. For specific key risk areas we have implemented dedicated rules, instructions on how to operate and pre-approvals processes.

Anti-Corruption policy

Trade compliance

We operate in a global environment and comply with applicable import and export controls laws, trade sanctions regulations and customs procedures, and expect our business partners to do the same. Accelleron has implemented specific controls to mitigate risks related to trade compliance, including screenings on suppliers and customers to avoid breaches of international sanctions, processes to comply with the dual-use regulations, and systems to ensure accurate declarations to trade authorities.

Privacy and Protection of Personal Data

In a world where personal data is constantly at risk from illicit cyber activity, we are fully committed to combatting these threats and ensuring compliance with the data privacy legislation in all territories where we operate. Protecting the personal data of our customers, suppliers and employees is a critical objective that we take very seriously.
We uphold a data privacy policy applicable to all our group companies, ensuring that parts of our organisation safeguard personal data to a high standard.

As part of our Code of Conduct, we ensure our employees are fully equipped to protect personal data through our policies and training, ensuing that data privacy is recognised as a critical element of their work. In accordance with legislation, Accelleron enables individuals to request access their personal data and provides transparency over activities where their data is used.

Antitrust and Competition Law

Complying with competition and antitrust requirements is non-negotiable. We believe in competing fairly, openly and independently, and our approach to conducting business is always guided by our business values in compliance with antitrust laws and regulation. Our Antitrust Policy ensures each employee lives by this commitment.

We believe in a competitive, free enterprise system that guarantees that our hard work and innovation is rewarded, and we know that we will lose the trust of our stakeholders if we conspire with competitors.
Antitrust laws are designed to protect competition, on the basis that fair competition is beneficial to the end consumer and the public at large. Our actions must always comply with all applicable antitrust and other laws regulating competition, and we conduct ourselves globally in a manner consistent with the principles of competition law.

Supply chain transparency

We only deal with suppliers who share our commitment to ethical business.

As a result, we expect our suppliers, contractors and other representatives to acknowledge and adhere to Accelleron’s Supplier Code of Conduct or to apply a similar set of integrity policies and procedures with respect to business with Accelleron.

Our Supplier Code of Conduct requires suppliers to conduct business respectfully and with high standard of integrity in all matters including human rights, health, safety and environmental management, bribery and corruption and conflict minerals.

Our Organisation

The Integrity Office within the Legal & Integrity team reports directly to Accelleron’s General Counsel and is responsible for designing, implementing and improving the Accelleron Integrity Program, ensuring that all policies and procedures are applied.

The Integrity Office works in close cooperation with all Accelleron employees who are expected to take ownership of the Code of Conduct and the Integrity Program and act as a role model for ethical conduct

Reporting Channels

We have a culture of openness and actively encourage our employees and stakeholders to report any concerns of illegality, wrongdoing or breaches of our Code of Conduct as soon as possible.

We have the mechanisms in place to enable them to voice their concerns quickly, easily and confidentially, through the SpeakUp hotline, which is open to employees and third-parties alike.

Incidents of known or suspected violations that are reported in good faith are protected against retaliation, and any inappropriate retaliation against employees is subject to strict disciplinary measures and sanctions.

Reporting can be made through various channels by

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