Our promise to act professionally and in accordance with applicable laws and ethical values towards each other, our clients and the capital markets requires integrity in our words and actions. We are clearly committed to the values set by KPMG in the form of a Code of Conduct. Questioning applicable laws or our values is unacceptable. To maintain our culture of integrity, KPMG has long maintained a whistleblowing hotline in Germany.
Which reporting offices does KPMG maintain?
In compliance with the legal requirements from the
- Law for better protection of whistleblowers (Whistleblower Protection Act)
- Law on Corporate Due Diligence in Supply Chains (Supply Chain Sourcing Obligations Act)
KPMG maintains the whistleblower reporting channels described in more detail below. The so-called "Whistleblowing Hotline" is designed as an internal reporting office in the sense of Section 14 Whistleblower Protection Act and at the same time fulfils the function of a complaints office in the sense of Section 8 Supply Chain Sourcing Obligations Act.
Who can use the Whistleblowing Hotline?
The whistleblowing hotline can be used by all employees within the meaning of Section 3 (8) Whistleblower Protection Act, but also by clients, subcontractors, suppliers and other third parties, including as a complaints office within the meaning of Section 8 Supply Chain Sourcing Obligations Act.
With what information can one contact the Whistleblowing Hotline?
The whistleblowing hotline enables the reporting of illegal or unethical actions when other channels of communication have proven to be less effective or inappropriate. In such cases, where effective internal action can be taken against a violation and the whistleblower does not have to fear reprisals, reporting to the Whistleblowing Hotline as an internal reporting point should be preferred.
The whistleblowing hotline can be used in particular for reporting and disclosing information on violations within the meaning of Section 2 Whistleblower Protection Act. This includes violations that are punishable by law or – insofar as the violated regulation serves the protection of life, body or health, the protection of the rights of employees or their representative bodies – are subject to a fine, or other violations of legal provisions, e. g. to combat money laundering and terrorist financing, the protection of personal data, the auditing of financial statements of companies of public interest or the accounting of companies that are capital market-oriented.
Furthermore, there is the possibility to point out human rights or environment-related risks as well as violations of human rights or environment-related obligations in the sense of Sections 8 and 9 Supply Chain Sourcing Obligations Act.
The whistleblowing hotline can also be used to report misconduct by KPMG employees in relation to professional standards or against self-imposed values in the form of the Code of Conduct.
We encourage everyone to raise a concern if it affects KPMG in Germany or its employees or management. If your concern relates to a KPMG firm that is not a group company of KPMG AG Wirtschaftsprüfungsgesellschaft, please contact that KPMG firm directly or use the KPMG International Hotline, which can be accessed via the details at the following link.
How can a report be submitted?
KPMG operates the whistleblowing hotline as an internal reporting office with the involvement of an external lawyer based in Berlin. The involvement of a person outside the organisation who is professionally bound to maintain confidentiality ensures confidentiality for all who make a report, anonymity for those who do not wish to disclose their name and impartiality as she is independent and not bound by instructions. The whistleblowing hotline offers the following options for making a report:
- By telephone using the following number:
+49 30 31 01 82 15
You can reach lawyer Dr. Margarete Gräfin von Galen under the telephone number. She can be reached during regular office hours (9.00 a.m. to 6.00 p.m.). Outside these office hours, an answering machine is available to take messages.
- By post or e-mail to the following contact details:
Rechtsanwältin Dr. Margarete Gräfin von Galen
- Use of a web-based online reporting system *
From here, the report is made available to Dr Margarete Gräfin von Galen, lawyer, and – unless notification is excluded by the person making the report – to a narrow circle of employees in Quality & Risk Management at KPMG.
What happens to a message?
Each notification is processed in accordance with the legal requirements (in particular Section 17 Whistleblower Protection Act and Sections 8 and 9 Supply Chain Sourcing Obligations Act).
The internal reporting office receives each report, confirms receipt, evaluates it, discusses the facts with the whistleblower and decides on the next steps to be taken in clarifying and investigating the report, depending on the violations and/or conspicuous features that are the subject of the report. This is done in consultation between Dr. Margarete Gräfin von Galen and the employees from the Quality and Risk Management department appointed in accordance with Section 15 Whistleblower Protection Act. The internal reporting office determines the follow-up measures in accordance with Section 18 Whistleblower Protection Act.
Dr Margarete Gräfin von Galen maintains contact with the informant and communicates the information about the conclusion of the investigation and the result found to him.
The content of every report and every reporting person within the scope of the Whistleblower Protection Act is subject to the protection of this Act. Reports are treated as strictly confidential; upon request, the anonymity of a whistleblower will be preserved by lawyer Dr Margarete Gräfin von Galen, also vis-à-vis KPMG employees in the internal reporting office.
Reports that do not concern KPMG in Germany but, for example, another KPMG company that is a member of the global KPMG organisation of independent member firms, are forwarded to KPMG International. If a report is forwarded to another group company of KPMG AG Wirtschaftsprüfungsgesellschaft or to KPMG International, it is subject to the appropriate rules for the protection of confidentiality and against retaliation.
KPMG encourages reporting violations of laws and ethical principles. Whistleblowers and in particular employees need not fear any negative consequences because of a report they have made or supported in good faith within the meaning of Sections 33 and 34 Whistleblower Protection Act. KPMG Germany's Code of Conduct prohibits sanctions against anyone who reports a possible violation in good faith or participates in an investigation, even if there is insufficient evidence to substantiate the concerns raised.
* KPMG in Germany cooperates with Clear View Strategic Partners** in Canada, an independent provider of web-based hotline services. Please note the instructions in the reporting system, especially with regard to the options for preserving anonymity.
** Clear View ConnectsTM is a registered trademark of ClearView Strategic Partners Inc.