Integrity and compliance are core principles at the Adecco Group.

The Adecco Group is committed to conducting its business affairs according to both the values stated in its Code of Conduct and the applicable laws and regulations in the places where the Group does business.

The Adecco Group fosters an environment of open and honest communication, and encourages all stakeholders to raise their questions or concerns and to report suspected violations of law or company policy without fear of retaliation.

One of the channels available for making an inquiry or a report of an actual or possible violation of Adecco Group’s Code of Conduct, a company policy, or an applicable law or regulation is the Adecco Compliance and Ethics Line (“ACE Line”). The ACE Line is open to colleagues, associates, candidates, clients, service providers, and other third parties. It assists any reporter to make written or phone reports, and is available 24 hours a day, 7 days a week with representatives who can consult in almost any language.

All reports submitted through the ACE Line are received directly by EthicsPoint and then routed to the Group Compliance Reporting Office (“GCRO”) at the Adecco Group, who will ensure that each report is handled in a professional and confidential manner and in line with Adecco Group’s investigation framework. The person submitting a report has the choice to do so anonymously, consistent with applicable law.

The GCRO is an independent function within the Adecco Group that reports directly to the Adecco Group Board of Directors instead of management.

The GCRO is responsible for the following activities across the Adecco Group:

• Administering the reporting hotline “ACE Line” and related intake channels of reports of misconduct (all reports made via the ACE Line are forwarded to the GCRO);
• Receiving reports about misconduct directly from line managers or colleagues or referrals of reports received by line managers or other sources;
• Following up and communicating with reporters through their preferred communication method (for anonymous reports this can be done online through the ACE Line while maintaining anonymity of the report);
• Conducting a case triage to evaluate and classify allegations according to the “Group Policy on Integrity & Compliance Report Management”;
• Assigning reports to, and periodically following up with, the appropriate investigation body;
• Obtaining the necessary approvals from, and periodically updating of, the Group’s Investigation Steering Committee, which conducts the oversight over all compliance investigations in the Group;
• Preparing periodic information to the Board’s Audit Committee about allegations received by the GCRO, the result of the investigations and the corrective actions that were taken.

The Adecco Group’s “ACE Line Reporting Guidelines” govern how reports should be made and addressed. These guidelines are available in the “ACE Line Reporting Guidelines” section of this website.

Code of Conduct

The importance of work, and what Adecco Group is doing to help people find it, cannot be overstated. Work can define who we are. It can give purpose and meaning to our lives. It permits us to apply our talents to contribute to society. It is essential for our personal and financial well-being. It is the means by which we can each realise our dreams.

Adecco Group’s success in helping others realise their dreams is based upon the trust and loyalty they have in us. Trust and loyalty are the most precious assets in any business, but it cannot be bought or manufactured, it must be earned.

We at Adecco Group are dedicated to earning the trust and loyalty of our colleagues, associates, clients, customers, shareholders, the communities in which we operate, by performing our work in accordance with our Code of Conduct and our core values of Team Spirit, Customer Centricity, Passion, Responsibility and Entrepreneurship.

The Code of Conduct can be downloaded using the link below:

• The Adecco Code of Conduct.
  Adobe Acrobat File (1.1 MB)
  

Frequently Asked Questions

The Adecco Group’s Group Compliance Reporting Office helps ensure that the company operates according to high standards of integrity and compliance and in adherence to both legal obligations and established internal procedures. The following are a set of questions and answers responding to frequently asked questions about using the ACE Line.

 

Q: Where does the Code of Conduct apply?
A: The Code of Conduct applies to all subsidiaries in all countries where the Adecco Group does business. Additionally, all colleagues are subject to the laws and regulations of the locations where they work.

Q: Does management really want me to report?
A: It certainly does. In fact, management needs you to report. Either as a colleague, as an associate or as an external stakeholder, you see what is going on in or with the company - both good and bad. You may know about an activity that may be a cause for concern. Your reporting can minimize the potential negative impact to the company and its stakeholders.

Q: What may I or should I report?
A: You may report any questions or concerns about an actual or possible violation of the law, the Code of Conduct, or company policies, standards, business practices, manuals, or procedures.

Q: To whom may I or should I report?
A: For employees of companies belonging to the Adecco Group, there are multiple channels available for making an inquiry or a report. Employees may direct an inquiry or report to any of the following:

• A supervisor or other member of management;
• The local, regional, corporate or brand Human Resources or Legal departments;
• Any member of the Group Compliance Reporting Office, Group Internal Audit or Group Function Integrity & Compliance departments;
• The Adecco Compliance and Ethics (“ACE”) Line; or
• Any member of the Board of Directors of Adecco Group AG.
• Additionally, reports may be directed specifically to any employees listed in the Annex to the ACE Line Reporting Guidelines.

If you are not employed by a company belonging to the Adecco Group, you may make reports to your Adecco Group contact or via the ACE Line.

The Group Compliance Reporting Office can also answer questions and respond to concerns about integrity and compliance and the requirements described in the Code of Conduct.

Q: If I see a violation, shouldn't I just report it to my manager, human resources, or Adecco Group contact (for external reporters) and let them deal with it?
A: You certainly can, but there are several reasons why you may want to use the ACE Line as well or alternatively. The ACE Line ensures that your report reaches the appropriate people. More importantly, subject to local legislation, reports can be filed anonymously, and all reported information is secure and held in confidence.

Q: What is a reporter?
A: A reporter is a person who provides information or raises a concern in good faith regarding suspected misconduct, mismanagement, waste of resources, and/ or abuse of authority involving the Adecco Group. In some countries, they are referred to as whistleblowers. Reporters can be current and former employees, associates, job applicants, shareholders, trainees, volunteers, contractors, self-employed individuals, service providers, suppliers, clients, and other third parties. In some countries, reporters can be protected under applicable laws.

Q: How does Adecco Group protect a reporter?
A: Adecco Group prohibits any form of retaliation, including threats and attempts to retaliate against employees and anyone who is protected under applicable laws when reporting suspected misconduct or raising concerns. Also, subject to local legislation, reporters may choose to remain anonymous when reporting such suspected misconduct or raising concerns.

Q: How does the ACE Line work?
A: If you submit a report online, the site will prompt you to provide the information that is required to investigate a concern. You will have the option to navigate the site in one of several languages. However, you may file your report in any language. You will have the choice to remain anonymous and your report will still be accepted, consistent with applicable law.

Once you have completed your report, you will be provided with a Report Key, and you will be asked to create a Password. You can return to the site later for an update. After reviewing your report, we may need to ask you questions in order to investigate the matter further. You will need to enter both your Report Key and your Password to access the site.

If you submit a report by telephone, your call will be answered in English by a qualified call center specialist. Depending on the language in which you wish to conduct the conversation, the call center specialist will either continue with the call, transfer it to a colleague who is able to speak your language, or ask an interpreter to join the conversation. The ACE Line supports all languages.

Q: What happens after I submit a report?
A: Once a report is made to the ACE Line, details of the report are sent to the Group Compliance Reporting Office (GCRO), an independent office within the Adecco Group that reports to the Audit Committee of the Board of Directors.

The GCRO acknowledges receipt of the report by responding to the Reporter. The GCRO reviews incoming reports for appropriate handling, communicates with the Reporter throughout the process to obtain any additional information, and tracks the progress of any investigations. If you make a report, the GCRO would like to keep in contact and communicate with you about this matter. The ability to have conversations usually greatly facilitates the investigation. Sometimes an initial report does not have enough information to make it possible to investigate the matter.

The scope of an investigation and the steps taken depend on the type of report and the specific situation.

Q: Are reports confidential?
A: Information regarding a report or an investigation is confidential and disclosed only on a need-to-know basis or as necessary to comply with applicable laws or regulations. The people who have a need to know may vary depending on the situation, but can include members of the Board of Directors, the Group’s Executive Committee, and individuals tasked with investigating the matter. Decisions about who has a need to know about an investigation are made in accordance with our Group Policy on Integrity & Compliance Report Management.

Q: Can reports be submitted anonymously? Do I need to identify myself?
A: We encourage you to identify yourself although it is not required. Adecco Group will accept anonymous reports, consistent with applicable law. No attempt is made to determine the number from which you are calling (caller ID is disabled). We understand the value of complaints provided by individuals who wish to remain anonymous. We also understand the value of being able to contact those who make reports to ask for additional information or clarification of the issues. If you decide to remain anonymous you can still communicate with us through the ACE Line, and we encourage you to do so. We would like to remain in contact with you because it greatly facilitates the investigation if there is ongoing communication. If you decide not to share your name, you can still communicate with us by logging into the tool with your Report Key and your Password.

Please be aware that (i) the request for anonymity could hinder or even prevent an investigation (if one is warranted), and (ii) total anonymity cannot be guaranteed. Adecco Group also cannot assure anonymity if a reporter identifies himself/ herself to others or provides information in the report that is likely to identify himself/ herself.

Q: Is the toll-free telephone hotline confidential and anonymous too?
A: Yes. You will be asked to provide the same information that you would provide in an Internet-based report and an interviewer will type your responses into the ACE Line Web site. These reports have the same security and confidentiality measures applied to them during delivery.

Q: When can I submit a report?
A: You can submit a report anytime, anywhere. The ACE Line is available 24 hours a day, 365 days a year, globally for both Internet and telephone reporting.

Q: What information should I be prepared to give?
A: Your report should tell us (1) what happened, (2) when it happened, (3) where it happened, (4) who was involved, (5) what was done and/or said, (6) whether there were any witnesses other than you, (7) where these other parties can be contacted, and (8) what documents may support your report. In order to protect the reputation and privacy rights of all parties, and to promote due process and the fairness of investigations, it is important that the information you provide be accurate and given in good faith.

Q: What if I want to identify myself in my report?
A: There is a section in the report for identifying yourself, if you wish.

Q: Will I get into trouble if I report an ethical concern, or if I suspect someone of violating the Code of Conduct, applicable laws or company policies?
A: No. Adecco Group prohibits any form of retaliation, intimidation, or disciplinary action against anyone who reports in good faith any concern regarding integrity and compliance. Any suspected retaliation should be reported to the ACE Line. However, any employee who makes a report that is not in good faith is exposed to disciplinary action, up to and including termination.

Likewise, if an employee makes a report involving his/her own misconduct, he/she will not be immune or otherwise protected from disciplinary measures or similar consequences.

Q: As a colleague, do I have to participate in an investigation?
A: Subject to local law, you are required to cooperate in an investigation. This means that you must make yourself available to assist with investigations, be truthful and forthcoming with investigators, and provide complete, accurate, and truthful information.

Additionally, you must exercise appropriate confidentiality regarding the subject matter of the investigation.

Q: As a colleague, what are the consequences for violating the Code of Conduct?
A: Colleagues who violate the Code of Conduct, company policies or applicable laws and regulations may be subject to disciplinary action, up to and including termination (subject to local labor laws and regulations). Those who violate the Code of Conduct may simultaneously violate applicable laws, regulations or policies. This may subject them to prosecution, imprisonment, and fines, and they may be required to reimburse the company and others for losses.

Q: Does an investigation ever lead to the prosecution of someone?
A: If deemed necessary, Adecco Group will contact law enforcement authorities. Adecco Group supports, as a matter of principle, the criminal prosecution of those involved in criminal conduct, regardless of whether any restitution is paid. When appropriate, Adecco Group will also institute civil proceeding against violators.

Q: How will I know a violation has been corrected?
A: If an investigation is warranted, allegations will be investigated thoroughly. Depending on the complexity of the matter, it may take time to investigate. For confidentiality reasons, you will not necessarily be told the specifics of how a particular matter is being investigated or how it has been resolved. However, you will be notified through the communication channel chosen by you when the report you submitted has come to a conclusion.

ACE Line Reporting Guidelines

Guidelines to Reporting to the “Adecco Compliance and Ethics” Line

The Adecco Group is committed to conducting its business affairs according to both the values stated in its Code of Conduct and the applicable laws and regulations in those places where Adecco Group does business. Adecco Group’s reputation is determined by the way each employee conducts his/her respective work duties. Illegal or improper behavior by even a single employee can cause Adecco Group considerable harm.

Adecco Group promotes a culture that encourages people to seek guidance, to raise any concerns they have relating to possibly improper business conduct, and to report any actual or suspected misconduct. Conducting an effective investigation allows Adecco Group to support the fair and consistent enforcement of workplace rules and to take immediate action to prevent further inappropriate behavior. These inquiries may lead to improvements in internal controls, business processes and practices, as well as the protection of Adecco Group’s financial and legal interests.

Internal Lines of Communication

Adecco Group’s culture expects from the Group’s employees a conscientious and ethically minded behavior and the commitment to integrity, honesty, transparency, openness and fairness. Employees have the responsibility to protect Adecco Group from conduct that can threaten its day-to-day operations, its reputation and future business growth, or cause other harm.

Adecco Group is committed to fostering dialogue between management and employees through multiple channels. Supervisors are expected to maintain an environment that promotes open communication. Adecco Group’s goal is that employees will know where to turn to when they have a question or concern about an actual or possible violation of Adecco Group’s Code of Conduct, an applicable law or regulation, or an Adecco policy, standard, business practice, manual or procedure (collectively, a “Business-Conduct Standard”).

Making a Report

There are multiple channels for making an inquiry or a report of an actual or possible violation of a Business-Conduct Standard. Employees may direct an inquiry or report to any of the following:

• A supervisor or other member of management;
• The human resources or legal departments;
• Any member of the Group Compliance Reporting Office (the “GCRO”), Group Internal Audit or Group Function Integrity & Compliance departments;
• The Adecco Compliance and Ethics (“ACE”) Line; or
• Any member of the Board of Directors of Adecco Group AG.

A report may also be directed specifically to any of the employees listed in the Annex to these guidelines.

The ACE Line

The ACE Line is a telephone and web resource, to assist employees and third parties with guidance or for making a report. Dialling instructions for calling the ACE Line may be found at www.aceconduct.com. The ACE Line is available anytime night or day. Translation services are also available. An online report may be made to the ACE Line.

The Reporter to the ACE Line will be asked to provide details of the incident or issue in the report. He/she will be asked to disclose his/her identity. The Reporter may decline to provide his/her identity, and Adecco Group will still accept the report. Adecco Group will accept anonymous reports, consistent with applicable law. However, employees should be advised (i) that the request for anonymity could hinder or even prevent an investigation (if one is warranted), and (ii) total anonymity cannot be guaranteed. Adecco Group also cannot assure anonymity if an employee identifies himself/herself to others or provides information in the report that is likely to identify himself/herself.

Reports to the ACE Line are considered carefully and handled confidentially. Additionally, third parties who are not employees are also invited to make a report by contacting the ACE Line.

Investigations of Reports

When a report is received, a preliminary assessment is made to determine whether an investigation is warranted. An investigation is warranted if there is a reasonable basis to believe that misconduct may have occurred. If an investigation is not warranted, the report may be referred to another department for handling.

The scope of an investigation and the steps taken are tailored to the nature of the report and the needs of the particular situation. Investigations are conducted objectively, professionally, efficiently, and completed in a timely manner. Investigations will be conducted according to Adecco Group’s Protocol for Conducting Investigations.

Information regarding an investigation or a report is confidential and disclosed only on a need-to-know basis or as necessary to comply with applicable laws or regulations.

The GCRO maintains appropriate records to document the report, the nature of the allegation, the investigation, the findings and any corrective actions recommended. These documents are confidential and maintained according to Adecco Group’s document-retention guidelines.

Corrective action may be taken once the investigation is complete, if appropriate. While any action taken as a result of an investigation will necessarily vary depending on the situation, Adecco Group’s management should strive for consistency by utilizing sound practices and disciplinary protocols.

Certain jurisdictions apply specific rules and restrictions regarding how a report may be made, if the report affects someone within that jurisdiction, or how the investigation may be conducted. Adecco Group complies with those rules and restrictions where applicable.

Additional Duties and Prohibitions

Adecco Group prohibits any form of retaliation, intimidation or disciplinary action against anyone who makes a report in good faith or participates in an investigation, even if it is ultimately concluded that no misconduct occurred. If an employee engages in retaliation or intimidation, he/she is subject to disciplinary action, up to and including termination.

If an employee makes a report involving his/her own misconduct, he/she will not be immune or otherwise protected from discipline or similar consequences.

If an employee makes a report that is not in good faith, he/she will be subject to disciplinary action, up to and including termination.

Employees are required to cooperate in an investigation. Employees must make themselves available to assist investigations immediately upon request, be fully forthcoming and truthful with investigators, and provide complete, accurate and truthful information. Employee cooperation includes producing and preserving any relevant documents in either hard-copy or electronic form.

If an employee attempts improperly to determine the identity of a reporter who makes an anonymous report, that employee may be subject to disciplinary action, up to and including termination.

Employees may not take any action that would be reasonably likely either to compromise the investigation or to affect negatively the status of anyone who may be involved in the investigation.

Consistent with applicable law, employees and third parties involved in the investigation, such as witnesses, must exercise appropriate discretion regarding the subject matter of the investigation. Similarly, anyone involved in the investigation must be careful to avoid communication, outside of the investigation process, of any information that may be construed as false, misleading, defamatory, or an invasion of privacy.

ANNEX A

Overview Code of Conduct Frequently Asked Questions ACE Line Reporting Guidelines