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.

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 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 

Make a report

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

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

When to use the KPMG International Hotline

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

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

• Audit Quality
• Quality of Service Delivery
• Independence or Conflicts of Interest
• Integrity of Financial Reporting, Accounting, Internal Controls
• Bribery, Corruption, Money Laundering, Fraud or other Illegal Acts
• Information Security or Privacy
• Ethics and Public Interest
• Discrimination, Bullying, Intimidation, Harassment, Victimisation or other inappropriate behaviour 
• Equality, Diversity and Inclusion
• Health & Safety

A more detailed description of the aforementioned categories will be available on the ClearView Connects system when you file a report.

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.

What will happen to your report

Your report will be reviewed by the KPMG International Global Regulatory Compliance Senior 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 & Risk Management and, where applicable, the KPMG International Office of General Counsel.

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.

Non-retaliation

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.

 

 

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