The KPMG International hotline is a vehicle for KPMG partners, employees, clients and other parties (such as trainees, interns, service providers or other business partners) to confidentially report concerns they have relating to certain areas of activity by KPMG International, KPMG member firms or the senior leadership of a KPMG member firm. KPMGI works with Canada-based ClearView Strategic Partners, a third party administrator of telephone and web-based hotline services (ClearView Connects) to operate the KPMG International hotline.

When to use the KPMG International hotline

You should make reports to this hotline in relation to the following:

• Accounting, including internal accounting controls;
• Auditing;
• Banking and financial crime, including money laundering and terrorist financing;
• Anti-bribery and corruption (including in relation to a client of a KPMG member firm, in so far as it affects KPMG); and
• Data security and privacy.

In addition, you can use the KPMG International hotline to report instances where you believe that either personnel of one of the member firms of the KPMG network, or reports issued by them, do not to comply with professional, regulatory or legal obligations. In particular we encourage reporting of such issues using this hotline if it relates to:

• KPMG International ("KPMGI");
• any KPMG member firm; or
• it concerns senior leadership of the relevant member firm.
  

Any abuse of the KPMG International hotline may result in action being taken against the perpetrators of the abuse. In the case of partners, employees or contractors of KPMG member firms, that action may include disciplinary action including dismissal. In the case of third parties this may include termination of commercial relationships and/or legal action. However, provided that you use the system in good faith, you will not face sanctions from us.

How to make a report

You can report concerns to the KPMG International hotline in three ways:

• By calling a toll-free number (PDF 216 KB) (open 24 hours a day, 7 days a week)
  
• By accessing a web-based reporting system at ClearView Connects (select KPMG International)
• Via mail to the following address:
  

ClearView Connects
P.O. Box 11017
Toronto, Ontario M1E 1N0
Canada

Both the web site and the telephone options are available 24-hours-a-day, seven days a week, and follow the same format for gathering information. Whether reporting through the hotline telephone number, the web site, or by mail, all reports are handled confidentially, to the extent permitted by law and consistent with KPMGI's requirement to investigate and address the reported conduct.

Anonymity and confidentiality

Using an external provider ensures confidentiality to anyone filing a report and anonymity to those who choose to remain anonymous. However, given the measures that are in place to provide for the confidentiality of reports and the details of individuals making good faith reports, we encourage you to give your name and contact details when making your report. Your identity will be kept confidential at all stages of the process and will not be disclosed to third parties or individuals who are the subject of your report.

The exceptions to this include where it is necessary to disclose information to relevant persons involved in any further investigation of the matter, where disclosure is required under a legal obligation, for example, for any subsequent judicial or administrative proceedings or where material access is requested by any regulatory or government authority which is not compulsory, but where the failure to comply would, in the reasonable opinion of KPMGI, worsen the working relationship with the authority. Further exceptions may apply based on applicable laws.

Notwithstanding the above, you should be aware that in order to conduct an appropriate investigation into matters raised by you, it may be necessary for us to advise others of the substance of your report. As such, your identity may become apparent and you should consider this before submitting your report.

If you wish to make your report anonymously using either the web site facility or a live telephone operator, then you will receive a password which will enable you to access the ClearView Connects case management system. This will allow us to communicate directly with you while preserving anonymity. If you forget or mislay your password then you will have to submit a new report in order to regain access to the system; in this event it would be helpful if you could refer to the previously submitted report to enable us to make the appropriate connections.

IMPORTANT: If an individual is a member of a German law, patent law, accounting, auditing or tax consulting firm, in no event may such an individual report client names or other client-identifying features to the confidential reporting system. Any breach of this prohibition may, because of the nature of German law, lead to serious sanctions including personal criminal liability. Precautions have also been implemented to prevent such disclosure. If an individual would like to report a matter involving or otherwise affecting a particular client, the individual should do so without identifying the client. When the report is assessed it will also be decided whether it is necessary to know the client’s name. If so, a way will be found to disclose such client’s name without infringing applicable laws and regulations.

What will happen to your report

Your report will be reviewed by the KPMG International Global Regulatory Compliance Manager who will determine the appropriate initial action. If your report concerns a member of Global Quality & Risk Management then you have the option to refer the report initially to a member of the KPMG International Office of General Counsel.

Many matters reported to the KPMG International hotline should be reported through KPMG member firm vehicles and investigated and resolved by the relevant member firm. If this is the case and it is possible to communicate with you (either through the ClearView Connects system or directly) you will generally be informed that the matter is being referred to a named individual in the member firm.

If it is not appropriate for the member firm to investigate the matter itself (for example where it concerns the senior leadership of the member firm) then the investigation will be conducted under the auspices of KPMG Global Quality and Risk Management and, where applicable, the KPMG International Office of General Counsel.

Non-retaliation

It is KPMGI’s policy to encourage people to report concerns (“raise their hand”) regarding matters in relation to the Global Code of Conduct, financial crime, anti-bribery, failure to comply with professional, regulatory or legal obligations, and engagement quality, without fear of retaliation in accordance with applicable law and regulation. All member firms are prohibited from retaliating against individuals who ‘raise their hand’ for good faith reporting.

Retaliation is a serious violation of our Global Code of Conduct. Any retaliation by a KPMG person is subject to disciplinary action, up to and, including dismissal.

Data privacy

Personal data which is processed in the context of the whistleblowing system will be transferred to ClearView Strategic Partners in Canada, a country which is recognized by the European Commission as providing a sufficient level of personal data protection, for the purpose of operating the KPMG International hotline.

Any individual whose personal data is processed in the context of the whistleblowing system, whether reporter or reported person has certain rights of rectification, erasure and access to any personal data of which they are the subject. These rights may be exercised by contacting (go-fmkpmginternation@kpmg.com). In the event that a reported person receives confirmation of a report and/or their personal data contained in a report, your identity will remain confidential and will not be disclosed (unless one of the exceptions set out above applies).

Reports are retained by those individuals involved in a KPMG International hotline investigation during the course of an investigation. Once an investigation is complete, reports containing personal information will generally only be retained for up to two years following the completion of the investigation. This is done in order to comply with data protection and privacy legislation. However, where the reports might reasonably be required as part of legal, regulatory or similar proceedings or by virtue of professional rules or obligations, full copies of reports, including any personal information, are retained for the relevant limitation period under applicable law.

Member firm hotlines

In addition to this hotline, several of the member firms of the KPMG network have their own formal complaints procedures, details of which can be obtained from the relevant websites or engagement letters. If your report relates to one of our member firms, before using the KPMG International hotline to see if there is another site or email address which better suits your needs.

Any questions about the operation of the KPMGI hotline should be directed to (go-fmkpmginternation@kpmg.com).

 

ClearView Connects™ is a registered trademark of ClearView Strategic Partners Inc.