The Whistle-blowing Hotline is a vehicle for KPMG partners, employees, clients and other parties to confidentially report concerns they have relating to certain areas of activity by KPMG in Russia and the CIS itself, its employees or the senior leadership of KPMG member firms. Further information is given below on when and how to use the Hotline, and on how your report will be dealt with.

When to use the Hotline:

Reports made to this Hotline should only be in relation to the following:

• Accounting;
• Internal accounting controls;
• Auditing;
• Banking crime;
• Financial crime; 
• Anti-bribery (including in relation to KPMG clients, in so far as it affects the firm).

In particular, we encourage reporting of the issues using this Hotline if:

• it relates to KPMG in Russia and the CIS itself or its employees; 
• it concerns senior leadership of KPMG in Russia and the CIS.

Complaints

The Whistle-blowing Hotline should not be used to raise formal complaints relating to the quality of KPMG services. The standard complaints procedures and/or engagement letters should be used in these instances.

You can use KPMG in Russia and the CIS Hotline or International one (choosing ‘KPMG in Russia and the CIS’ or ‘KPMG International’ when entering the ClearView Connects system). The International Hotline can be used if your report relates to certain areas of activity by KPMG International, operation of KPMG CIS or the Senior leadership of KPMG CIS (e.g. where you believe that either personnel of KPMG CIS or report issued by them do not comply with professional, regulatory or legal obligations).

How to make a report

There are several ways that you can submit a report – use ClearView online system, speak with a ClearView agent, leave a voicemail report or mail a hard copy report.

• By accessing the Web-based reporting system at www.clearviewconnects.com
- Select KPMG in Russia and the CIS to report the issue related to the member firm's business;
- Choose KPMG International if your report relates to certain areas of activity by KPMG International, operation or the Senior leadership of KPMG CIS.

• By calling:
- toll free number for Russia: 810 800 2026 2012 - please note that calls from mobiles might be charged and that this number is not accessible if you are calling from outside the country.
- toll free number for Ukraine: 0 800 50 3166
- toll free number for Kazakhstan: 8 800 3337624
- for other CIS countries: 1 647 438 6817

• By reporting surface mail:
ClearView Connects™
P.O. Box 11017
Toronto, Ontario
M1E 1N0

Both the Web site and the phone 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 post, all reports are handled confidentially, to the extent permitted by law and consistent with KPMG member firm’s requirements to investigate and address the reported conduct.

Given the measures that are in place to ensure the confidentiality of reports and the details of individuals making reports, we encourage you to give your name and contact details when making you 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 for any subsequent judicial proceedings or where access is requested by any regulatory authority. However, 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.

What will happen to your report

If your report if it concerns KPMG in Russia and CIS, it will be reviewed by the Ombudsman for KPMG in Russia and CIS and a member of Quality and Risk Management team to determine the investigative action plan.

If your report concerns a member of Quality & Risk Management then your report will be referred solely to the Ombudsman.

If you have reported the issue to the International Hotline, it will be reviewed by the KPMG International Global Regulatory Compliance Manager who will determine the appropriate action plan.

Reports we receive which do not fall within the scope of this Hotline (for example, because they relate to a different KPMG member firm) will either be referred to the appropriate firm, or to KPMG International. In any case, your report will be subject to appropriate confidentiality and a non-retaliation policy.

Confidentiality

KPMG is working with Canada-based Clearview Strategic Partners, a third party administrator of telephone and Web-based hotline services to operate the organization’s hotline. Using an external provider ensures confidentiality to anyone filing a report and anonymity to those who choose to remain anonymous. Notwithstanding this, 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.

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