Ethics and Compliance Hotline

You can report concerns to the KPMG in Canada Ethics and Compliance Hotline in the following ways:

1. By accessing the web-based reporting system at www.clearviewconnects.com (select KPMG Canada)
   
2. By calling the KPMG in Canada dedicated toll-free number:  +1 833 554 5107

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 KPMG in Canada’s requirement to investigate and address the reported conduct.

KPMG International or other KPMG firms

In addition to the Canadian hotline, KPMG International has its own hotline operated by ClearView Connects. If your report relates to another member firm, you may use the KPMG International Hotline.

KPMG’s hotline can be used to confidentially disclose concerns.

You can use the hotline to report instances where you believe that either personnel of the firm, or reports issued by them, do not to comply with professional, regulatory or legal obligations.

In addition, you can use the KPMG International Hotline to report instances where you believe that either personnel of KPMG in Canada or any 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
• It concerns senior leadership of the relevant member firm

Examples of the types of areas on which you can make a report:

Where a KPMG firm or KPMG personnel are considered to have failed to meet the appropriate standards of quality in relation to an audit conducted by a KPMG firm.

Quality of service has not met the quality standards set by KPMG and / or do not meet the terms set out in the engagement contract.

Where a KPMG firm or KPMG personnel are considered to have breached independence rules that apply to them (e.g. Holding a prohibited financial interest in a client, providing prohibited non-audit services).

A conflict of interest occurs when a person's or entity's vested interests raise a question of whether their actions, judgment, and / or decision-making can be unbiased and / or objective. In business, a conflict of interest arises when a person chooses personal gain over duties to their employer, or to an organization in which they are a stakeholder or exploits their position for personal gain in some way.

Items regarding:

• The accuracy and completeness of financial statements and other financial records or reporting
• Accounting, internal accounting controls or auditing matters

Authorized or unauthorized changes made to any data, information or reports in order to manipulate or falsify documents or records for purposes such as:

• Covering mistakes or fraud
• Improving financial or operational results
• Gaining unfair advantage in a contract
  

Where a KPMG firm or any KPMG personnel are either:

• Believed to be involved in, or
• Considered to have failed to appropriately respond where a client (or its management) is involved in, any activity that is or may be illegal in any relevant jurisdiction, including but not limited to, offering or accepting bribes, offering facilitation payments, the corruption of government officials, money laundering, insider dealing, fraud, and/or tax evasion.

Any activity or situation that could pose a risk to data, data security or privacy of information, including unauthorized access, hacking, theft or tampering.

Where the behaviour of a KPMG firm or KPMG personnel, KPMG clients or suppliers, or public officials with whom KPMG deals is considered to be in breach of the KPMG code of conduct and where such behaviour is considered to be illegal, unethical or breaches human rights.

Items related to the well-being of people in the workplace, including:

• Discrimination of any nature, including based on ethnicity, place of origin, religion, gender, sexual orientation, age or disability
• Unethical conduct or behaviour
• Violence or threat of violence
• Substance abuse
• Victimization via bullying and intimidation by co-workers, being denied a promotion or being moved to a position with lower responsibility; dismissal from employment, or being refused further contract work.
  

Items related to the well-being of people in the workplace, including discrimination of any nature, including based on ethnicity, place of origin, religion, gender, sexual orientation, age or disability.

Matters relating to, but not limited to, the recruitment, movement, harbouring or receiving of children, women or men through the use of force, coercion, abuse of vulnerability, deception or other means for the purpose of exploitation.

KPMG has a non-retaliation policy in respect of all individuals who make reports in good faith.

It is KPMG in Canada’s policy to encourage people to report concerns (“raise their hand”) 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 Canadian Code of Conduct. Any retaliation by a KPMG person is subject to disciplinary action, up to and including dismissal.

Examples of what might constitute unacceptable retaliation include, but are not limited to:

• Suspension, lay-off, dismissal or equivalent measures
• Demotion or withholding of promotion
• Transfer of duties, change of location of place of work, reduction in wages, change in working hours
• Withholding of training
• A negative performance assessment or employment reference
• Imposition or administering of any disciplinary measure, reprimand, or other penalty, including a financial penalty
• Coercion, intimidation, harassment or ostracism
• Discrimination, disadvantageous or unfair treatment
• Failure to convert a temporary employment contract into a permanent one, where the worker had legitimate expectations that he or she would be offered permanent employment
• Failure to renew, or early termination of, a temporary employment contract
• Harm, including to the person’s reputation, particularly in social media, or financial loss, including loss of business and loss of income
• Blacklisting on the basis of a sector or industry-wide informal or formal agreement, which may entail that the person will not, in the future, find employment in the sector or industry
• Early termination
• Psychiatric or medical referrals
  

Upon receipt of your report appropriate initial action will be determined.

Your report will be reviewed by the Canadian Managing Partner in Quality Risk Management or HR Officer who will, depending on the nature of the reported matter, determine the appropriate initial action.

Many matters reported to the 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 KPMG in Canada to investigate the matter itself (for example where it concerns the senior leadership of the firm), then the investigation will be conducted under the auspices of the KPMG International Office of General Counsel or by KPMG International Quality and Risk Management where applicable.

The KPMG in Canada hotline allows KPMG Stakeholders to speak up in a confidential environment.

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 KPMG in Canada, 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.

Adhering to data protection and privacy legislation, personal data that are processed in the context of the KPMG in Canada Ethics and Compliance Hotline will be transferred to ClearView Strategic Partners.

Any individual whose personal data is processed in the context of the KPMG in Canada Ethics and Compliance Hotline, whether reporter or reported person, shall be subject to the ClearView Strategic Partners privacy policy, and such other privacy-related materials as may be provided or made available to you by ClearView Strategic Partners.

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 under Anonymity and confidentiality applies).

Reports are retained by those individuals involved in a KPMG in Canada 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.

Your report will be shared by ClearView Strategic Partners with KPMG in Canada personnel who are involved in the management, administration and investigation of matters reported through the KPMG in Canada Ethics and Compliance Hotline.

For more details as to how KPMG processes your personal information, please see the KPMG in Canada Privacy Policy.