Our commitments as a principled business
2.3 RESPECTING PROPERTY AND DATA 2.3.1 INSIDER TRADING Insider information is explicit, confidential information which, if made public, might impact on the company’s share price.
Accor pledges to ensure strict compliance with the market rules applicable to employees who may have access to insider information.
YOU SHOULD ALWAYS ̸ protect the secrecy of insider or privileged information to which you may have access.
YOU SHOULD NEVER ̸ use insider information for your own advantage (or that of family and friends) or for your (or their) investments. If you do, you may be liable to criminal prosecution, administrative penalties or disciplinary sanctions; ̸ disclose insider information to any individual working for the Group or outside it.
IS THIS ETHICAL?
Situation: I have discovered that the Group is about to invest in a number of countries and acquire a competitor. This information has not yet been made public but I thought I might suggest to my parents that they take advantage of the opportunity by purchasing Accor shares. Can you do this?
Solution: absolutely not. You are in possession of explicit, confidential, non-public information which, if it were known to the public, might impact on Accor’s share price. You should not buy or sell Group shares until this information has been made public nor should you pass this information on to anyone inside or outside the company. If you do, you will be liable to disciplinary sanctions and severe criminal law punishments. 2.3.2 CONFLICTS OF INTEREST A conflict of interest occurs when the employee’s personal or private interests (financial, business, family or other relationships) may influence or simply appear to influence a decision made by the employee in the course of his/her duty. While respecting the personal life of its employees, the Group expects them to proactively avoid conflicts of interest. In the context of their professional activities, all Accor employees must act at all times in the interest of the Group.
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Accor has introduced rules, procedures and guidelines for disclosing conflicts of interest. In particular, since 2010, senior executives have been prohibited from acquiring any equity interest in a company owning one or more hotels franchised or managed under an Accor brand.
Accor also requires all employees to disclose any situation where there may be a conflict of interest as soon as they become aware of it, and as far as possible, before taking action.
