KPMG International hotline

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

• By accessing a web-based reporting system at www.clearviewconnects.com (select KPMG International)
• By calling a toll-free number (PDF 216 KB) (open 24 hours a day, 7 days a week)

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.

The KPMG International 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 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, such an individual report should avoid client names or other client-identifying features to the confidential reporting system. If an individual would like to report a matter involving or otherwise affecting a particular German client, the individual should do so without identifying the client or use the whistleblowing hotline of KPMG Germany (phone: +49 (0) 30 / 31 01 82 15; email: galen@galen.de). 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.

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

Your report will be reviewed by the KPMG International Hotline Team which sits within the KPMG International Office of General Counsel. The Team will determine the appropriate initial action.

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 the KPMG International Office of General Counsel or by KPMG Global Quality & Risk Management where applicable.

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

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

It is KPMGI'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 Global 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; or
• Psychiatric or medical referrals.

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 under Anonymity and confidentiality 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.

For more details as to how KPMG processes your personal information, please see the privacy statement.