Legal notices

Last updated: March 2024

Privacy Notice

1. Introduction

Accelya Global Limited and its related companies (“Accelya”, “We” or “Us”) are responsible for processing the personal data identified in this Privacy Notice as a controller of such personal data. A list of the Accelya related companies can be found at Section 15 (Related Accelya Companies) of this Privacy Notice.

We are committed to protecting the personal data and this Privacy Notice aims to explain how We collect, use, share and process personal data in our businesses. Should you have any questions, please see our contact details Section 14 (DPO and other contacts).

We reserve the right to make changes to our practices and this Privacy Notice at any time. We invite you to regular check this Privacy Notice from time to time for any updates or changes.

This Privacy Notice does not apply where We process personal data on behalf of our customers. For detailed privacy information related to an Accelya customer who uses Accelya products and services as the controller, please contact the applicable customer directly. We are not responsible for the privacy compliance of our customers, which may differ from those explained in this Privacy Notice.

2. What is personal data?

Personal data is any information about an identified or identifiable person. Personal data can include information, such as a person’s name, address or date of birth, but also less obvious information, such as an identification number, customer number, order number, or photograph.

3. When do We collect personal data?

This Privacy Notices applies to our processing of your personal data when you:

• visit one of our offices;
• visit our websites or our social media pages;
• register for and take part in an event We organise or sponsor;
• take part in market research or client surveys conducted by Us;
• communicate with Us, whether by email, telephone, or other means;
• are employed by a service provider to, or customer of, Accelya and your information has been shared with Us in our capacity as a controller (for example, during the contracting process).

4. What personal data do We collect?

When We collect personal data about the individuals We interact with through our businesses, We may collect the following types of information:

5. Why do We need your personal data?

We collect and process your personal data for the following purposes and based upon the following established legal bases:

6. Who do We disclose your personal data to?

We share your personal data with the following categories of third parties.  We require such third parties to respect the security of your data and to treat it in accordance with the relevant local law. We do not sell any of your personal data to others.

This website may contain links to other sites. Please be aware that Accelya is not responsible for the privacy practices of these third party sites. We encourage you to be aware when you leave Our website and to read the privacy statements of each website you visit. This Privacy Notice applies solely to personal data We collect and process as a controller.

7. Where do We transfer your data?

Your personal data is stored mainly on servers in the European Union. However, We operate globally and may transfer your personal information to other related Accelya companies, service providers, and other third parties (identified in Section 6 (Who do We disclose your personal data to?) of this Privacy Notice) in other countries that are not subject to an adequacy decision by the European Commission or applicable regulatory authorities.

Where your personal data is transferred to countries outside the European Union, UK or Switzerland, We will take steps to ensure your information is adequately protected, for example, by entering into the standard contractual clauses approved by the European Commission or other applicable regulatory authority, or put in place other approved lawful measures to ensure that such transfer provides adequate safeguards.

8. For how long do We keep your personal data?

The period for which We retain your personal data will be determined by numerous factors, including how long it takes Us to perform the activity for which your personal data was collected. We will also take into account the nature of the personal data, any applicable legal requirements We are subject to and any potential risks that may arise from unauthorised access.

9. Cookies and related technologies

We use, and allow third party service providers to use, cookies, web beacons and other similar technologies on our platforms, social media pages and communications. We do this to understand your use of our services, improve your user experience and enable personalised features and content, optimise our advertising and marketing, and to enable third party advertising companies to assist Us in serving ads specific to your interests across the Internet. For more information on the cookies We use please refer to our ‘Cookie Settings’ tab at the bottom of our website.

If you wish to change your preferences regarding the use of our cookies, you may configure your web browser to either request your specific acceptance of a cookie or disable cookies entirely (other than strictly necessary cookies). You will still be able to fully navigate our websites if you choose to refuse or disable cookies.

10. How do We protect your personal data?

Accelya takes steps to apply appropriate security measures so that your personal data is protected against unauthorised or unlawful processing and against accidental loss, damage or destruction or disclosure.

Where possible we limit access to personal data to those individuals or third parties who need to access it for the purpose for which it was collected. However, no set of security measures is ever completely effective against all cyber security threats.

11. What are your rights?

In accordance with applicable law, you may have the following rights in relation to the personal data We collect and process in accordance with this Privacy Notice:

These rights may be limited in some situations – for example, where We can demonstrate that We have a legal requirement or contractual obligation to process your personal data.

Where the processing of your personal information is based on your consent, you have the right to withdraw your consent at any time to prevent any further processing based upon your previous consent.

If you wish to exercise any of the rights set out above, please log your request using our webform: Accelya Data Right Webform or please contact [email protected].

If you are located in the European Economic Area or the UK, you have the right to lodge complaints about the processing of your personal data with your relevant data protection regulator. For more information on this, please see Section 14 (DPO and other contacts) of this Privacy Notice.

12. Do We process children’s personal data?

We do not target our websites, services, or events at children. No information should be submitted by any person under 18 years of age. Unless otherwise disclosed during collection, Accelya does not knowingly collect any personal data about any person under 18 years of age. If you wish to notify Us of any unintentional collection of personal data relating to a person under 18 years of age, please contact Us using the details found at Section 14 (DPO and other contacts) of this Privacy Notice.

13. Country-specific privacy disclosures

Brazil

If you reside in Brazil or otherwise subject to the Federal Law nº 13.709/18 (“LGPD”), you are entitled to several rights in respect of your personal data under LGPD. In addition to the rights granted to you in Section n 11 (What are your rights?) of this Privacy Notice, you may also exercise the following rights when applicable.

Right to Petition – You may petition with the Brazilian regulatory authority as well as consumer protection entities regarding the processing of your personal data.

If you are a Brazilian resident and you wish to contact Us about exercising your rights in relation to your personal data, you can do so using the details set out in Section 14  (DPO and other contacts) of this Privacy Notice.

If your personal data is subject to the LGPD, We will take all necessary measures to ensure that transfers out of Brazil are adequately protected as required by applicable data protection law.

14. DPO and other contacts

If you have any questions about this Privacy Notice, our data protection practices or want to log a complaint about our compliance with applicable privacy laws, please contact Us using the ‘Contact us’ tab at the bottom of our website or, alternatively, contacting [email protected].

If you are a resident within the European Economic Area or the UK, you have the right to log a complaint with the relevant data protection supervisory authority. If you wish to write to our Data Protection Officer, you may do so using the following details:

– Accelya Group – FAO: The DPO, West, Watchmoor Park, Riverside Way Building 10, First Floor, Camberley GU15 3YL

– Email: Contact [email protected]

If you wish to exercise any of your rights in relation to your personal data, you can log your request using our webform: Accelya Data Right Webform or otherwise contact [email protected]

Accelya reserves the right to change or otherwise update this Privacy Notice at any time. Such changes or updates are effective immediately after We give notice of the change or update, which We may do so by revising the “Last Updated” date of this Privacy Notice or by otherwise posting the changes or updates on our websites or by email or conventional mail and/or by other means that provides reasonable notice.

Your use of our website after such notice is posted means that you accept these changes or updates. You agree that Accelya shall not be liable to you for any damage that might result from any changes to the Privacy Notice.

15. Related Accelya Companies

Our related Accelya companies are:

Last updated: October 2024

About this Notice

Ensuring our customers’ safety is our primary concern. At Accelya, we incorporate security into our products from design through development and release via our Secure Development Lifecycle. However, some vulnerabilities may escape detection, or new exploits may emerge after the product is on the market.

We investigate all vulnerability reports and take the best course of action to protect our customers. If you are a security researcher and have discovered a security vulnerability in our products, we appreciate your responsible disclosure.

In compliance with our Responsible Disclosure Policy, if you identify a verified vulnerability, we commit to:

• Acknowledge receipt of your vulnerability report within 48 business hours.
• Work closely with you to understand the issue and agree on timelines for fixing and disclosing it.
• Notify you when the vulnerability is resolved, so you can re-test and confirm the remediation.
• Publicly acknowledge your responsible disclosure, if you wish.

Please contact us at [email protected]

Accelya’s CIO and General Counsel review our Vulnerability Disclosure Policy annually from both legal and operational perspectives.

Last updated: March 2024

About this Notice

This Privacy Notice applies to all candidates applying for a job position with Accelya Global Limited (and its subsidiaries) (the “Company”, “we” or “us”).

For the purposes of UK and EU data protection laws (where they apply), the relevant “controller” of your personal data is, usually, the company within the Accelya group that employs or engages you (or may potentially employ or engage you, if you are a prospective employee or contractor). It is the “controller” of your personal data that decides how and why your personal information is held and used.

We are required under data protection legislation to notify you of the information contained in this Privacy Notice.

We value the privacy of those who provide personal information to us. Please read this Privacy Notice carefully to understand how we handle your personal information. This Privacy Notice describes:

• what personal information we collect about our potential employees
• how we use and otherwise process it;
• the basis upon which we process it;
• with whom it is shared; and
• how it is stored.

This notice also describes other important topics relating to information privacy.

Please note that you may have different or additional rights in respect of your personal information depending upon your location. Please contact the Data Protection Officer for Accelya, whose email address is [email protected] for more information.

1. Who does this notice apply to?

1.1 This Privacy Notice applies to all prospective employees of the Company.

1.2 It applies to all your personal data that we process in the context of your job application and prospective employment.

2. Data protection principles

We will comply with applicable data protection and privacy laws. These provide that the personal data we hold about you must be:

(a) used lawfully, fairly and in a transparent way;

(b) collected only for valid purposes that we have clearly explained to you and not used in any way that is incompatible with those purposes;

(c) relevant to the purposes we have told you about and limited only to those purposes;

(d) accurate and kept up to date;

(e) kept only as long as necessary for the purposes we have told you about, except where otherwise required to be retained for longer pursuant to laws applicable to us; and

(f) kept securely, both physically and electronically.

3. The information that we hold about you

3.1 Personal data, or personal information, means any information about an individual from which that individual can be identified. It does not include data which cannot be linked to an individual in any way (i.e. anonymous data).

3.2 There are “special categories” of more sensitive personal data which require a higher level of protection and we have set out more details about this at section 7 below.

3.3 Information collection

3.4 We collect, store and use any of the following categories of information about you and we refer to this as “personal information” or “personal data” throughout this Privacy Notice:

(a) Your personal details: name and title, gender, birth date, home address and home/personal phone number and email address marital status and military status (where permitted under local laws).

(b) Talent management/resume/CV information: when you apply for a job or work with us/for us, we need to collect and hold details contained in an application and resume/CV or otherwise provided to or obtained by us, including personal and contact details, previous employment background, professional qualifications and memberships, references. We may also collect and hold career development and skills analysis, training, education, departmental changes, performance, calibration details.

(c) Any information you provide to us during an interview.

(d) CCAT test results (and/or other critical thinking or suitability assessment results).

4. How is your information collected?

4.1 We will receive most of this personal information from you directly including through the application and recruitment process or via a recruitment agency. During this process we will collect your application details including your name, location, contact details (email and phone), work history and any other information you may have provided in relation to your application.

4.2 We may collect information directly from you in a variety of ways. For example, data might be collected through application forms, CVs/resumes, obtained from your passport or other identity documents such as your driving licence, from forms completed by you at the start of or during employment/engagement (such as benefit nomination forms), from correspondence with you, or through interviews, meetings, or other assessments.

4.3 We may also receive some of information from third parties for example specialist screening companies, social media, online searches (including LinkedIn), training providers, CCAT test (and/or other critical thinking or assessment) providers, medical professionals or occupational health providers, former employers and other referees and public agencies.

4.4 We will also collect additional personal information during the course of job-related activities throughout the period of you working for us, should you be successful in securing a role with Accelya.

5. Use of your personal information

5.1 We collect, use and store your personal information for a number of purposes, including those set out in ‘Appendix 1 – Lawful Grounds for processing Personal Data’ of this Privacy Notice.

6. Our lawful grounds for using your personal information

6.1 Please note that this section only applies to you if you are located in, or potentially applying for roles in, the UK or the EEA.

6.2 In order to comply with data privacy laws in the UK and the EEA, we need to have lawful bases for using your personal information for the purposes set out in this Privacy Notice. We have set out more detail about the lawful bases we rely on to process your data in ‘Appendix 1 – Lawful Grounds for processing Personal Data’. We consider that in nearly all cases, our lawful basis will be one or more of the following:

(a) Your express consent through your application;
(b) It is in our legitimate interests to use the personal information we collect about you to decide whether to appoint you to the role which you applied for;
(c) We also need to process your personal information to decide whether to enter into a contract of employment with you.

7. Why we collect and use sensitive personal data

7.1 Sensitive personal data, so called “special categories” of personal data, require higher levels of protection. We need to have further justification for collecting, storing and using this. Special category data is personal data relating to racial or ethnic origins; political opinions; religious and philosophical beliefs; trade union membership; genetic data; biometric data; health data; sex life or sexual orientation. We may process special categories of personal data in the following circumstances:

(a) In limited circumstances, with your explicit written consent and, where local laws require additional conditions to be complied with, provided such local requirements are met.
(b) We will use information about your disability status to consider whether we need to provide appropriate adjustments during the recruitment process, for example whether adjustments need to be made during a test or interview.
(c) We will use information about your race or national or ethnic origin, religious, philosophical or moral beliefs, or your sexual life or sexual orientation, only if you choose to provide it and to ensure meaningful equal opportunity monitoring and reporting.

7.2 We do not currently request or gather any information regarding political opinions, philosophical belief or trade union membership.

7.3 Where it is permitted and/or required by law to do so or given the nature of the role, we may collect information about criminal convictions as part of the recruitment process in order to satisfy ourselves that there is nothing in your criminal convictions history which makes you unsuitable for the role. or we may be notified of such information directly by you in the course of you working for us.

7.4 As part of the recruitment process, we may engage a third-party provider to carry out background checks on our behalf relating to criminal convictions (in the UK, these are referred to as DBS checks); education history; prior employment history and global sanctions and enforcement. We and our third party provider rely upon your explicit consent as the appropriate ground and condition for processing of such data.

8. How we share your personal information (and who with)

8.1 We may have to share your data with third parties, including third-party service providers and other entities within the Accelya group.

8.2 Disclosure within the Accelya group:

(a) Your personal information may be shared with any company that is a member of the Company group. Access to your personal information is limited to those employees who need to know the personal information, and may include your prospective managers and their designees, as well as employees in the HR and recruitment teams. Our Company entities are as below:

(b) We may also share your personal information with our group companies where they provide products and services to us, such as IT systems, data hosting, HR services, legal support, payroll and benefits administration and recruitment.

8.3 Disclosure to other third parties:

(a) We will share your personal data with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so.

(b) We may share your personal information with the following third parties for the purposes of processing your application:

(A) HR services, such as external advisors, applicant tracking providers/systems;

(B) third party providers who carry out background and pre-screening checks (including e-verification relating to residency, work permit and/or visa checks) on our behalf;

(C) third party providers who issue and score CCAT tests (and/or other technical, critical thinking and suitability assessments) on our behalf;

(D) cloud storage or other IT service providers;

(E) police and immigration authorities;

(F) IT systems suppliers and support, including providers of HR systems and benefits management, email archiving, telecommunications suppliers, back-up and disaster recovery and cyber security services; and other outsourcing providers, such as contract lease management, and off-site storage providers.

(c) We will also disclose your personal information to third parties in some other circumstances if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, any lawful request from government or law enforcement officials and as may be required to meet national security or law enforcement requirements or prevent illegal activity.

8.4 Restrictions on use of your personal information by those we share it with

(a) Any third parties with whom we share your personal information are limited (by law and/or by contract) in their ability to use your personal information and the purposes for which they use it. In respect of third party service providers who are processing data on our behalf, we only permit them to process personal data for specified purposes and in accordance with our instructions.

(b) Other than as we have set out in this Privacy Notice, we will not share your personal information with any third party without notifying you and/or obtaining your consent.

9. Transfers of information

9.1 Please note that this section 11 only applies if you are located in, or potentially applying for, roles in the UK or the EEA.

9.2 When transferring personal information outside the UK and the EEA, we will:

(a) ensure that the country in which your personal information will be processed has been deemed “adequate” by the relevant UK authorities and/or by the European Commission (as applicable); or

(b) include the standard contractual data protection clauses approved by relevant authorities in the UK and/or EEA (as applicable) for transferring personal information outside the UK and/or EEA, into our contracts with other members of our group or third parties.

9.3 Further details on the steps we take to protect your personal information in these cases is available from us on request by contacting the Human Resources team at the Accelya company for which you work or the Data Protection Officer for Accelya, whose email address is [email protected].

10. Retention of personal information

10.1 We have identified retention guidelines for different types of HR data taking into account the purpose for which data is collected, statutory obligations in respect of the retention of data and limitation periods for the bringing of claims where the data may be evidentially relevant.

10.2 For unsuccessful job applicants, the indicative retention period for data is 1 year from the date of our decision.

10.3 We retain personal information following recruitment exercises to demonstrate, if required, that candidates have not been discriminated against on prohibited grounds and that recruitment exercises are conducted in a fair and transparent way. We may also retain personal information following recruitment exercises to enable us to consider unsuccessful candidates for other job opportunities (subject to the candidate’s express consent, where required pursuant to applicable local laws).

10.4 In some circumstances we (and/or third parties) may anonymize your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

10.5 Once it is no longer necessary to retain your personal information, we will securely destroy it in accordance with applicable laws and regulations.

11. Change of purpose

11.1 We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the lawful basis which allows us to do so (which may require us to obtain your consent for the new purpose).

11.2 Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by local law.

12. Your rights

12.1 You have certain rights in relation to your personal information. If you would like further information in relation to these or would like to exercise any one of them, please contact the Human Resources team at the Accelya company for which you have applied to work or the Data Protection Officer for Accelya, whose email address is [email protected].

12.2 In certain circumstances (and subject to local law requirements), you have the right to request that we:

(a) provide you with a copy of any personal information which we hold about you;

(b) update any of your personal information which is out of date or incorrect or incomplete;

(c) delete any personal information which we hold about you if it is no longer necessary in relation to the purposes for which it was collected or processed (or, in some instances, where you have withdrawn your consent or objected to the processing);

(d) restrict the way that we process your personal information;

(e) provide your personal information to a third party;

(f) consider any valid objections which you have to our use of your personal information (where we are relying on our legitimate interests (or those of a third party) as the basis for the processing or that the processing is in the public interest); and

(g) provide a copy of any agreement under which your personal data is transferred outside of the UK and EEA (for UK and EEA staff).

12.3 We will consider all such requests and provide our response within the time period stated by applicable law. Please note, however, that certain personal information may be exempt from such requests in certain circumstances, which may include if we need to keep processing your personal information for our legitimate interests or to comply with a legal obligation. There will be certain circumstances where the right does not apply to you under law and we will review this when we consider a request.

12.4 We may request you provide us with information necessary to confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

12.5 You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.

12.6 If you have any questions or concerns about our use of your personal information, please contact the Human Resources team at the Accelya company for which you have applied to work or the data protection officer for Accelya, whose email address is [email protected].

13. Right to withdraw consent

13.1 In the limited circumstances where our processing is based on your having provided consent to the collection, processing and transfer of your personal data for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

13.2 To withdraw your consent, please contact Accelya´s privacy team at [email protected]. Where these circumstances apply, once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.

14. Keeping us updated

It is important that the personal information we hold about you is accurate and current. Please ensure that any personal information you share with us (or third parties engaged by us) is accurate, and keep us informed if your personal information changes during your working relationship with us.

15. Security

15.1 The Company is committed to protecting personal information from loss, misuse, disclosure, alteration, unauthorised access and destruction and takes appropriate administrative, physical and technical precautions to safeguard the confidentiality and security of personal information. Although we make every effort to protect the personal information which you provide to us, the transmission of information over the internet is not completely secure. As such, you acknowledge that we cannot guarantee the security of your personal information transmitted to us over the internet that any such transmission is at your own risk. Once we have received your personal information, we will use strict procedures and security features to prevent unauthorised access.

15.2 Where we have given you (or where you have chosen) a password which enables you to access any account with us, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

16. Automated decision-making

Automated decision-making takes place when an electronic system uses personal information to make a decision without human intervention, and that decision produces a legal or similarly significant effect on you (for example, this would be the case if we decided whether to offer you a job solely based on automated processing of your personal information). We do not engage in that type of automated decision-making and we will notify you in writing if this position changes.

17. Third party websites

You may, from time to time, during your application, access links to or other websites operated by third parties (e.g. Workday or CCAT exams providers). Please note that this Privacy Notice only applies to the personal information that we collect from or about you and we cannot be responsible for personal information collected and stored by third parties. Third party websites have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to these websites. We do not endorse or otherwise accept any responsibility or liability for the content of such third party websites or third party terms and conditions or policies.

18. Changes to our Privacy Notice

This Privacy Notice may be amended from time to time. Any changes we make to this Privacy Notice in the future will be posted on our website. Please check back frequently to see any updates or changes.

19. Further questions or making a complaint

19.1 If you have any queries or complaints about our collection, use or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact Accelya’s privacy team, whose email address is [email protected]. We will investigate and attempt to resolve any such complaint or dispute regarding the use or disclosure of your personal information.

19.2 Local laws may allow you to also make a complaint to the relevant local data protection supervisory authority (e.g. in the UK, the Information Commissioner’s Office (https://ico.org.uk/)). Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

The practices described in this Privacy Notice statement are current personal information protection policies, as of 01 February 2024.

If you have any questions about this Privacy Notice, please contact the Human Resources team at the Accelya company for which you have applied to work or the data protection officer for Accelya, whose email address is [email protected].

Appendix 1 – Lawful Grounds for processing Personal Data

Last updated: October 2024

Accelya Modern Slavery Statement 2024

This statement is made pursuant to the requirements of the UK Modern Slavery Act of 2015 and covers Accelya Global Limited (“Accelya“) and all affiliated companies under its control (the “Accelya Group“).

It is our responsibility, both as a business and as individuals, to tackle Modern Slavery. We will not tolerate, facilitate or condone any form of Modern Slavery within our organisation or anywhere in our supply chain.

Background to Accelya

Accelya is a leading global technology and service provider to the air transport industry delivering innovative change at speed and scale.

The company´s market-leading passenger, cargo, and industry platforms support airline retailing from offer to settlement, both above and below the wing.

Over 250 airline customers count on Accelya, with operations spread across nine countries and employing over 2,500 professionals worldwide.

For more than 40 years, Accelya has been the industry’s partner for change, simplifying airline financial and commercial processes and empowering the air transport community to take better control of the future.

Whether partnering with IATA on industry-wide initiatives or enabling digital transformation to simplify airline processes, Accelya drives the airline industry forward and proudly puts control back in the hands of airlines so they can move further, faster.

Our Supply Chain

We have a global complex and diverse supply chain, the majority of our business is the provision of professional and technological services to major business across the world and as such we do not produce physical goods.

We source goods and services from a global, diverse and complex supply chain.

The top 20 suppliers to the Accelya Group, who mostly provide professional services or IT software / hardware, approximately account for 75% of our spend. While many of these suppliers are based outside the UK, we still consider the risk of slavery and human trafficking within our supply chain to be low based on factors such as sector (operating in the IT industry) and types of suppliers (IT and support functions, mostly large international companies with their own published codes of conduct and modern slavery transparency statements).

Our approach to tackling Modern Slavery

We have a zero tolerance policy to Modern slavery and have not identified it within our business or with any third party or customer we deal with.

Since the financial year ending 2019 and the introduction of our Group Code of Conduct we have taken a number of steps to improve our approach to identifying and raising awareness of Modern slavery.

In the last year we have expanded our approach to tackling Modern Slavery:

• We have updated our Code of Conduct to include Modern Slavery.
• We have produced a specific Modern Slavery Policy.
• We have delivered Modern Slavery awareness training to all employees.
• We have begun the roll out our Supplier Code of Conduct to all suppliers asking them to make a commitment to have a zero tolerance policy to Modern Slavery, so far over 50% of our top 25% of suppliers by spend have agreed.

In the financial year ending June 2025 we will continue to review our policies and procedures in particular the continued roll out of the Supplier Code of Conduct to all our suppliers, engaging with them to gain their commitment to a zero tolerance policy and to which they must all adhere.

This statement is made pursuant to section 54(1) of the Modern Slavery Act 2015 and constitutes our transparency in supply chain statement for the financial year ending 30 June 2024

On behalf of Accelya Group Limited

Sam Gilliland – Chief Executive Officer

Last updated: October 2024

Human Rights Statement

At Accelya we are committed to upholding Human Rights and especially to treat people with dignity and respect, to foster a culture of diversity and inclusion, to actively promote equal opportunities for all.

We uphold and are committed to the principles of the United Nations Universal Declaration on Human Rights (available here ).

We demonstrate our commitment to Human Rights as signatories to the United Nations Global Compact and through our Code of Conduct which sets out our expectations for all our employees.

Our People

We value diversity and are committed to creating an inclusive culture and will not tolerate any form of discrimination or harassment of our employees. We are an equal opportunity employer. Employment opportunities are available regardless of ethnicity, religion, national origin, sex and sexual orientation, age, marital status or disability.

The health and safety of our employees and visitors to our premises is of paramount importance to Accelya and we are committed to ensuring that we undertake our business in such a manner that we do not harm the health or safety of our employees or anyone else affected by our activities products or services.

We are committed to complying with all national and international Health and Safety laws and regulations in all countries in which we operate.
We encourage all employees to report any concerns, suspected or confirmed, through our independent whistleblowing service, without fear of retaliation.

Our Supply Chain

We have a global complex and diverse supply chain, the majority of our business is the provision of professional and technological services to major business across the world and as such we do not produce physical goods.

Our relationship with our suppliers is an integral part of our commitment to Human Rights and trading both ethically and sustainably. We therefore endeavour to extend these standards to all our suppliers and partners. Our Supplier Code of Conduct, reviwed annually, identifies the mandatory minimum requirements of doing business with Accelya and we require all our suppliers and business partners to commit to it or to provide evidence of their own commitment to upholding human rights.

On behalf of Accelya Group Limited

Sam Gilliland – Chief Executive Officer

This statement will be reviewed annually by the ESG team and updated to ensure compliance with both legal requirements and best practice.

Last updated: September 2017

Agreement to terms

Please read these Accelya Website Terms of Use (“Terms”) carefully as they are a binding agreement between You and Accelya. By accessing or using any website or page which links to these Terms (“Website”), you agree to be bound by the Terms and to comply with applicable laws, including export control laws and regulations. Accelya also offers Software-as-a-Service and other products pursuant to a separate manually or digitally-executed agreement.

The Website contains a variety of information and resources including, but not limited to, product descriptions, text, images, photographs, documents, testimonials, logos, diagrams, reports, software, download areas, communication forums, and other tools (collectively the “Materials”).

If you do not agree to these Terms, do not use the Website or any Materials contained therein.

Accounts

You may be asked to input information to access certain areas of the Website, download certain Materials, register for events, or create an account. You agree to provide accurate and up-to-date information. Information you provide to Accelya during any input process, as well as all other information collected about you when you visit the Website, will be governed by Accelya’s Privacy Policy.

You understand and agree that you are responsible for maintaining the confidentiality of your account passwords. You agree that you will be solely responsible to Accelya for all activities that occur under your account. You agree to notify Accelya immediately of any unauthorized use of, or other security breach related to, your account.

Materials

The Materials are protected by copyright, trademark, patent, and other applicable laws. No license or other rights are granted except as expressly stated in these Terms. You may use the Materials solely for informational and noncommercial purposes. Unless expressly authorized by Accelya or otherwise permitted by law, you may not copy, publish, display, distribute, alter or make derivative works of any Materials. You may not remove, alter, or obscure any proprietary notices on any Materials. Products mentioned in the Materials may not be generally available in your geographical country or region. Product descriptions are subject to change at Accelya’s discretion.

Submissions

You are entirely responsible for anything that you upload, post, display, or otherwise transmit to or via the Website, including, but not limited to, software code, articles, feedback, or suggestions (“Submission”). You agree that you own all rights in and to any Submission, or that you have obtained the necessary rights and/or permissions to make the Submission. Each Submission must comply with the applicable acceptable use policy.

You give Accelya, its affiliated companies, and sublicenses a perpetual, irrevocable, transferable, worldwide, royalty-free, and non-exclusive license to reproduce, adapt, modify, translate, publish, publicly perform, publicly display, and distribute any Submission. Accelya is under no obligation to post or use any Submission, and Accelya may remove any Submission at any time in its sole discretion.

Hyperlinks

Accelya is not responsible for any third-party content or linked websites provided on the Website. The provision of any link does not imply Accelya’s endorsement of the website and is provided only as a convenience.

Disclaimer of warranty

Use of the website and of any materials are at your own risk. All materials are provided “as is”, with no warranties or guarantees whatsoever. Accelya expressly disclaims to the fullest extent permitted by law all express, implied, statutory, and other warranties, guarantees, or representations, including, without limitation, the warranties of merchantability, fitness for a particular purpose, and non-infringement of proprietary and intellectual property rights. Without limitation, Accelya makes no warranty or guarantee that the website or any materials will be uninterrupted, timely, secure, or error-free. These exclusions of warranties will apply to you to the fullest extent allowed by law.

Limitation of liability

In no event will Accelya be liable to any party for any direct, indirect, incidental, special, punitive or consequential damages of any type whatsoever related to or arising from the website or use of the materials, or of any site or resource linked to, referenced, or accessed through the website. This exclusion and waiver of liability includes, without limitation, any lost profits, business interruption, lost savings or loss of data, even if Accelya is expressly advised of the possibility of such damages. This exclusion and waiver of liability applies to all causes of action, no matter the legal theories, and will apply to the fullest extent permissible by law.

General

These Terms govern your use of the Website and constitute the entire legal agreement between you and Accelya relating thereto. Additional or different terms, conditions, and notices may apply to specific components of Materials offered through the Website. In the event of any conflict, such additional or different terms, conditions, and notices will prevail over these Terms. Please see the applicable agreement or notice. Accelya reserves all rights not expressly granted under these Terms, including intellectual property rights, and no other rights are granted under these Terms by implication or estoppel or otherwise. Accelya may update these Terms from time to time. Accelya will change the Last Updated date at the bottom of these Terms when it does so. It is your responsibility to check these Terms regularly. Accelya’s failure to enforce any legal right or remedy contained in these Terms or applicable law shall not be deemed a formal waiver of those rights or remedies and those rights or remedies will still be available to Accelya. If a court of competent jurisdiction deems any provision of these Terms invalid, the remaining provisions of these Terms will be unaffected.

© 2017 Accelya, Inc. All rights reserved. Accelya and the Accelya logo are trademarks of Accelya. All other brand and product names are trademarks or registered trademarks of their respective holders.

Last updated: March 2024

Cookies and related technologies

Cookies are small text files that websites send to your computer, mobile device or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.

We use, and allow third party service providers to use, cookies, web beacons and other similar technologies on our platforms, social media pages and communications. We do this to understand your use of our services; improve your user experience and enable personalised features and content; optimise our advertising and marketing and to enable third party advertising companies to assist us in serving ads specific to your interests across the Internet. View a full list of cookies and update your preferences in the Cookie Settings tab on our websites.

The cookies that We use can be categorised as follows:

Necessary: Necessary cookies are required to enable the basic features of this site, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.

Functional: Functional cookies help perform certain functionalities like sharing the content of the website on social media platforms, collecting feedback, and other third-party features.

Performance: Performance cookies are used to understand and analyze the key performance indexes of the website which helps in delivering a better user experience for our website visitors.

Advertising: Advertisement cookies are used to provide visitors with customized advertisements based on the pages you visited previously and to analyze the effectiveness of the ad campaigns.

Your preferences:

If you are concerned about the use of cookies, you can change your preferences any time by clicking the “Cookie Settings” tab at the bottom of our website or the cookie icon at the left of our website. This will let you revisit the cookie consent banner and change your preferences or withdraw your consent.

You may configure your web browser settings to either request your specific acceptance of a cookie or disable/block and delete cookies entirely (other than strictly necessary cookies).

Last updated: March 2024

Cookies are small text files that websites send to your computer, mobile device or other Internet-connected device to uniquely identify your browser or to store information or settings in your browser.

We use a number of ‘session cookies’ on our External Career Site. ‘Session cookies’ are temporary cookies which only last from the time you launch our website, until the time you leave the website or close your browser.

We use the following session cookies in our External Career Site:

If you have any questions about our cookie policy, please contact [email protected]