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DATA PROTECTION & PRIVACY NOTICE

Effective as of January 6, 2025

The data privacy regulations of some countries require that a person making a report containing personal data must be notified of certain collection and retention practices regarding the information submitted by that person through this service.

If you do not wish to accept the terms below, we may be unable to accept any information through this system and suggest you report this matter directly to your supervisor or manager or to a representative of the Human Resources Department or Legal and Compliance Department, depending on the nature of the possible violation.

General

The Accion Ethics Hotline (“Ethics Hotline”) is a web and phone-based intake system provided by Accion International and its affiliates, including its investment management subsidiary Accion Impact Management LLC (collectively, “Accion”, “we”, “us” or “our”), headquartered at 1101 15th St. NW, Suite 400, Washington, DC 20005 to its employees, vendors, suppliers and business partners (“Reporter(s)”) for reporting suspected violations of laws or regulations or for certain matters specified in an applicable whistleblowing law. In some jurisdictions, suspected violations of company policies may also be reportable through the Ethics Hotline. Depending on the jurisdiction, suspected violations of company policies might not fall into material scope of a specific whistleblower regulation. Such matters should be reported directly to your manager or a representative of the Human Resources Department or Legal and Compliance Department, as appropriate.

Accion is the controller of the processing, and NAVEX is a processor acting on behalf of Accion.

You may contact Accion with any questions relating to this Notice or Ethics Hotline as follows:

c/o Human Resources Department
Cc: Legal and Compliance Department
1101 15th St. NW, Suite 400
Washington, DC 20005
HR@accion.org
legal@accion.org

Use of the Ethics Hotline

Use of the Ethics Hotline is entirely voluntary. You are encouraged to report possible violations directly to your manager, or to a representative of the Human Resources Department or Legal and Compliance Department, depending on the nature of the possible violation. If you feel that you are unable to do so, you may use the Ethics Hotline to make your report, where legally permissible.

For more information click here.

The Ethics Hotline is a confidential online reporting system that allows you to report suspected violations of law or company policies, as well as other concerns you may have, to Accion.

Please be aware that the information you supply about yourself, your colleagues, or any aspect of Accion’s operations may result in decisions that affect others. Therefore, we ask that you only provide information that you believe is true. You will not be subject to retaliation from Accion for any report of a suspected violation that is made in good faith, even if it later turns out to be factually incorrect. Please be aware, however, that knowingly providing false or misleading information will not be tolerated. The information you submit will be treated confidentially except in cases where this is not possible because of legal requirements or in order to conduct an investigation, in which case the information will be handled sensitively. We encourage you to identify yourself in order for us to follow up with questions we may have.

What personal data and information is collected and processed?

The Ethics Hotline captures the following personal data and information that you provide when you make a report: (i) your name and contact details (unless you report anonymously, where legally permissible) and whether you are employed by Accion; (ii) the name and other personal data of the persons you name in your report if you provide such information (i.e., name of employer, title, description of functions and contact details); and (iii) a description of the alleged misconduct as well as a description of the circumstances of the incident (including the date of the incident). Note that depending upon the laws of the country in which you are residing, the report may not be made anonymously; however, your personal data will be treated confidentially and will only be disclosed as set out below.

How will the personal data and information be processed after your report and who may access personal data and information?

The purpose for which your personal data, and your report, will be used will be to investigate the issues raised in your report and to take appropriate follow-up action, in accordance with applicable law.

The personal data and information you provide will be stored in a database which is located on servers hosted and operated in the United States by NAVEX.

NAVEX has entered into contractual commitments with Accion to secure the information you provide in accordance with applicable law. NAVEX is committed to maintaining stringent privacy and security practices including those related to notice, choice, onward transfer, security, data integrity, access, and enforcement.

You may contact Accion with any requests relating to the use, transfer, correction, or deletion of any of your personal data stored by this Ethics Hotline at:

c/o Human Resources Department
Cc: Legal and Compliance Department
1101 15th St. NW, Suite 400
Washington, DC 20005
HR@accion.org
legal@accion.org

For more information click here.

For the purpose of processing and investigating your report and subject to the provisions of local law, the personal data and information you provide may be accessed, processed and used by the relevant personnel of Accion, including Human Resources, Legal and Compliance, management, external advisors (e.g. legal advisors) or other Accion representatives or, in limited circumstances, by technical staff at NAVEX. Those individuals may be located in the United States, the United Kingdom or elsewhere.

Personal data and information you provide may also be disclosed to the police and/or other enforcement or regulatory authorities. The relevant bodies that receive and process personal data can be located in the US or in another country that may not provide the level of data protection available in the EU.

Accessing Information Concerning the Report

Accion will promptly notify any person who is the subject of a report to the Ethics Hotline except where notice needs to be delayed to ensure the integrity of the investigation and preservation of relevant information.

For more information click here.

With some exceptions, the subject of the report may access information concerning the report (with the exception of the identity of the Reporter) and request correction of personal data that is inaccurate or incomplete in accordance with applicable law. Similarly, with some exceptions, Reporters may also access information about the report and request corrections of their personal data in accordance with applicable law.

Legal Basis for Processing

Accion collects, receives, uses, stores and otherwise processes personal data to comply with its legal obligations and in furtherance of its legitimate interests where these interests are not overridden by data protection rights, including:

to provide a safe reporting channel to employees and, where applicable, third parties, in compliance with the applicable law relating to protection of whistleblowers;
to investigate, respond to any reports and take follow up actions;
to administer the case management system associated with the Ethics Hotline;
to communicate with individuals and to verify an individual’s identity when they contact Accion or when Accion contacts them;
where relevant, for the establishment, exercise or defense of legal claims;
to protect and enforce the rights, property or safety of Accion, its stakeholders or other third parties;
for information security (including to detect, investigate, monitor, remediate and/or prevent security or cyber incidents), to prevent fraud, and for statistical and trend analysis; and
for any other purpose that Accion specifically notifies individuals about when we obtain personal data about them.

Retention of the Report and of Your Data

Your report and your personal data will only be retained for as long as they are needed for the investigation of your allegations, for any legitimate follow-up to the investigation, or as otherwise consistent with law; they will be fully and securely destroyed or erased when and as soon as they are no longer needed for the investigation of the report, or for the purposes of legitimate follow-up to the report (including legal action). However, reports and files on the investigation of reports (or parts of such reports or files) and personal data in such reports or files may be placed in an archive if there is a clear and overriding public interest or legal interest of Accion in retaining the data, subject to such restrictions on access to the data aimed at safeguarding the rights and freedoms of the data subjects as may be allowed by applicable law.

Your Rights

Accion will support you in exercise of any rights you may have as a data subject under applicable law, i.e., your:

right of access to your data;
right to rectification of incorrect data;
right to erasure of data (“right to be forgotten”);
right to ask for restriction (“blocking”) of contested data;
right to have third parties who received incorrect, incomplete or contested data informed of any rectifications or blocking of your data;
right to data portability;
right to object to processing; and
right not to be subject to automated decision-making including profiling (in fact we will not use your data or any information in your report for such decision-making).

For more information click here.

We will only restrict any of the above rights if and to the extent that that is necessary and proportionate in order to safeguard any of the major public interests recognized in applicable law such as the protection of criminal investigations or public security, or to protect the fundamental rights and freedoms of others, including any person(s) incriminated in your report, in accordance with applicable law.

In addition to the rights listed above, you may also have the right to lodge a complaint about our processing of your personal data with the authority competent for supervising the processing of personal data (often referred to as the data protection authority) in the country where you live (if that is an EU/EEA Member State) or in the country Accion is based (if you live outside the EU/EEA).

Transfers of Personal Data

Your report and your details may be held on the secure servers of NAVEX located in the United States; may be transferred to NAVEX sub-processors outside the United States for service and support or translation and interpretation purposes; subject to appropriate safeguards.

Special Country Regulations

Some countries restrict reports such that only employees in key or management functions may be the subject of a report. In some countries, anonymous reports may not be permitted under the law except under extremely restrictive circumstances.

Further, any issues or concerns relating to topics not in scope to be reported via the Ethics Hotline for a particular country or jurisdiction should be reported directly to your manager or a representative of the Human Resources Department or Legal and Compliance Department as appropriate.