GROUP POLICY Bribery and Corruption Prevention

1 GROUP POLICY Bribery and Corruption Prevention Effective date: Last modified: Document No. GP Replaces Version: Page 1 of 8 Adecco GROUP AG GROUP POLICY Bribery and Corruption Prevention Page 1 of 8 Table of Contents 1. Applicability and Responsibility ..1 2. Definitions ..1 3. POLICY Statement ..3 4. What this POLICY Requires ..3 5. Gifts and Hospitality ..4 6. Agents and Suppliers ..5 7. Charitable Contributions, Political Contributions ..5 8. Exigent Circumstances ..5 9. Compliance, Monitoring and Sanctions ..6 10. Approval / Amendments ..6 1. Applicability and Responsibility 1 This GROUP POLICY applies to all Employees of the Adecco GROUP . This GROUP POLICY applies to all locations and situations where Adecco GROUP business is conducted. 2 This GROUP POLICY is administered by the GROUP Compliance Office, which can be contacted in case of questions or needed clarifications.

2 3 This GROUP POLICY specifies minimum standards that must be adopted and implemented throughout the Adecco GROUP even if local legislation specifies less-stringent laws and regulations. When applicable laws and regulations require higher standards, it is the responsibility of each Country Manager and Global Business Head to adopt such higher standards for their organization. 4 Each Country Manager and Global Business Head is responsible for the proper implementation of this GROUP POLICY . 2. Definitions 1 The Adecco GROUP (or the company ) collectively means the Adecco GROUP , its business units, subsidiaries and affiliated companies throughout the world. 2 An Agent means any third party which acts on behalf of the Adecco GROUP and makes binding commitments on its behalf. For purposes of this GROUP POLICY , an Agent also includes third parties acting as intermediaries to (i) promote the company s commercial interests regarding a single transaction or project, (ii) interact on the company s behalf with a Government Official for governmental services, or (iii) introduce the company to one or more parties for the purpose of GROUP POLICY Bribery and Corruption Prevention Effective date: Last modified: Document No.

3 GP Replaces Version: Page 2 of 8 Adecco GROUP AG GROUP POLICY Bribery and Corruption Prevention Page 2 of 8 obtaining or retaining business. For purposes of clarity, Adecco GROUP s clients, Employees and associates are not Agents. 3 A bribe is giving, receiving or offering to a Government Official or to a private person an undue reward with the intention of influencing someone to do something improper. Bribes are used to obtain or keep a business advantage. Anything of value can be a bribe. Examples of what can constitute a bribe include: Cash, cash equivalents ( , gift checks) or loans. Payments for travel or entertainment or other hospitality of any person, their family members or associates. Favors, including offers of employment to any person, their family members or associates. Gifts to any person, their family members or associates.

4 Donations to a charity affiliated with or sponsored by any person, his/her family members or associates. Contributions to political parties or candidates. 4 A Charitable Contribution means a gift, loan, advance or deposit of money or anything of value by and on behalf of the Adecco GROUP to an organization organized and operated for a charitable purpose. 5 An Employee means a colleague employed by the Adecco GROUP as well as any company directors and officers. Local Management may, at its option, bind certain associates to this POLICY if these associates are first informed of the requirements of this GROUP POLICY . 6 A Facilitation Payment means a small payment made to a Government Official to speed up the performance of a duty they are already obliged to do. 7 A Government Official includes any official or employee of the following: Any local, state, provincial or national government; A political party or a candidate for political office; A government-owned or controlled business or company; An international non-governmental organization; or A close relative ( , a parent, sibling, spouse or child) of any of the above.

5 8 The Local Management means the company management staff of (i) a GROUP -level function, and (ii) each country or global business, led by a Country Manager, Global Business Head, or the equivalent person. 9 A Political Contribution means a gift, loan, advance or deposit of money or anything of value by and on behalf of the Adecco GROUP to a candidate for public office, a political party or organization, or a ballot initiative. 10 Supplier means any third party which provides goods or services to the Adecco GROUP but has neither authority to make legally binding commitments on behalf of the Adecco GROUP nor GROUP POLICY Bribery and Corruption Prevention Effective date: Last modified: Document No. GP Replaces Version: Page 3 of 8 Adecco GROUP AG GROUP POLICY Bribery and Corruption Prevention Page 3 of 8 the responsibilities of an Agent.

6 For purposes of clarity, Adecco GROUP s clients, Employees and associates are not Suppliers. 3. POLICY Statement 1 The Adecco GROUP has a zero-tolerance approach to Bribery and Corruption . We will only conduct business in compliance with the law. The company will not give, authorize or pay for a bribe to anyone in order to improperly influence that individual to act favorably towards the company. Similarly, the company will not allow an Employee to request or agree to receive a bribe. The company also requires that all business transactions are accurately reflected on its books and records. 2 The Adecco GROUP expects its Agents and Suppliers to comply with applicable legislation when conducting business with or acting on behalf of the Adecco GROUP . 3 In order to achieve these objectives, Adecco GROUP establishes core business standards, to be adopted and supplemented by Local Management.

7 Furthermore, procedures are specified, by which reports of actual or suspected violations of this GROUP POLICY may be received, investigated and reported appropriately within the company. Within this framework of minimum standards, the diverse cultural environments in which the company operates must be taken into consideration. This diversity may require Local Management to adapt certain business-practices policies to ensure they are fair, appropriate and applicable to meet local needs and applicable legislation. 4 In order to provide a proper tone from the top, each Country Manager and Global Business Head should provide explicit and visible support and commitment to this GROUP POLICY . 4. What this POLICY Requires 1 No Employee may offer, promise or give a bribe, whether directly or indirectly, to a Government Official or a private party to induce that person to take any action or make any decision that will give the company an improper business advantage.

8 2 No Employee may request or agree to receive a bribe, whether directly or indirectly, in order to allow a current or proposed Agent or Supplier to retain or obtain a commercial business relationship with the company, or to gain an improper advantage in the conduct of business with the company. 3 This POLICY expressly prohibits Facilitation Payments, regardless of their size and how often they are paid, made directly or indirectly to a Government Official on the company s behalf. 4 The Adecco GROUP further requires that Employees: Always follow the company s internal policies and procedures relating to the Prevention and detection of Bribery and Corruption , especially in the areas of business gifts and hospitality, charitable contributions, and political donations; Carefully select acquisition targets and appropriately monitor their activities to identify and address potential Bribery issues; Carefully select Agents and Suppliers and appropriately monitor their activities to identify and address potential Bribery issues; GROUP POLICY Bribery and Corruption Prevention Effective date: Last modified: Document No.

9 GP Replaces Version: Page 4 of 8 Adecco GROUP AG GROUP POLICY Bribery and Corruption Prevention Page 4 of 8 Comply with the applicable record-keeping requirements to enable the company to demonstrate its compliance with applicable Bribery and Corruption legislation; Comply with the company s system of financial and accounting procedures, including its system of internal controls, Promptly and appropriately report to the company any suspected violations of this POLICY ; and Avoid any conduct that could violate applicable legislation or even raise the appearance of activity which would be prohibited under this GROUP POLICY . 5 This GROUP POLICY and the company s anti- Bribery and Corruption standards and procedures will be reviewed periodically. These materials will be updated and adapted, as appropriate, to ensure their continued effectiveness.

10 6 All Employees will receive periodic training to ensure that Adecco s anti- Bribery and Corruption POLICY , standards and procedures are communicated effectively. Periodical certifications by all such Employees will be completed as part of the training process. 7 In order to implement this GROUP POLICY , Local Management will take each of the steps specified in Annex 1 to this GROUP POLICY . 5. Gifts and Hospitality 1 Adecco GROUP recognizes that accepting or offering gifts or hospitality is customary and part of typical business practices. The practice of giving business gifts and taking part in corporate hospitality varies between countries, regions and client industries, and what may be normal and acceptable in one place may not be in another. It is a matter to be approached prudently by all Employees.