Ethics Alert Line in Monaco

Ethics Alert Line in Monaco

In accordance with Law No. 1.457 of 12 December 2017 on harassment and violence at work in Monaco and KPMG International policy, you have an "Ethics alert line in Monaco" Hotline.

The Hotline is set up through an outside organization based in Canada, Cleaview Strategic Partners. All KPMG staff members will have access to it to bring to the attention of the Company a breach in the following areas:

  • Accounting ;
  • Internal control ;
  • Banking and financial crime;
  • Corruption ;
  • Money laundering;
  • Professional obligations;
  • Threat or serious harm to the general interest, personally known.

No employee may be sanctioned, dismissed or be the subject of a discriminatory measure, direct or indirect, for having reported a breach, in good faith, of a situation via this Hotline, even if the facts are proven by the inaccurate or do not give rise to any follow-up.

However, misuse of this device may expose its author to disciplinary sanctions as well as legal proceedings.

On the other hand, it is recalled that there is no obligation to make a report through the Hotline, and no sanction can or can be taken against an employee who decides not to make use of the Hotline.

Access to the Hotline

You have three options for accessing the Hotline.

1. Online platformwww.connexionsclearview.com

2. Address:

ClearView Connections
Box 11017
Toronto, Ontario
M1E 1N0
Canada

3. Dedicated phone line and voice mail

Please consult the KPMG International chart to locate the toll-free number for the country you are calling from.

If you call the hotline from a work phone, cell phone, or payphone and the call does not go through, please try again from a private landline. If there is no toll-free number for your country, you can call the hotline at +1 647 438 6817 (collect calls accepted) or use Skype to make an audio call at clearview-connects (see below ).

How to call ClearView Connects using Skype Audio

  1. Launch the Skype app from your computer or mobile device.
  2. In the search bar, type: clearview-connects
  3. Select ClearView Connects
  4. Click the Call button located at the top right of the app to make an audio call.

Note: You do not need to add ClearView to your Skype contacts. ClearView only accepts audio calls.

What happens to your report?

A report, if it proves to be objective and relevant in relation to the scope of the alert system defined above, may be the subject of a confidential report by the organization managing the Hotline intended for the Risk Management Partner of KPMG GLD & Associés (Bernard Squecco).

Confidentiality and security of data collected

In accordance with the Monegasque legal and regulatory provisions in force and governing the protection of personal data, only these persons may be recipients of this report. Confidentialité et sécurité des données recueillies

As indicated, alerts are collected through a Hotline. To do this, KPMG works with Clearview Strategic Partners.

This collaboration makes it possible to guarantee the confidentiality of the data collected as well as relevant and objective processing of alerts.

All the security measures and precautions necessary to ensure the security and confidentiality of the data, both during the collection and their communication or storage, are taken by KPMG.

In accordance with the legal and regulatory provisions in force:

  • The identity of the person issuing an alert is treated confidentially,
  • The person who wishes to remain anonymous will be able to do so, but their report can only be processed if the seriousness of the facts mentioned is established and the factual elements are sufficiently detailed,
  • Elements likely to identify the issuer of the alert cannot be disclosed without the express consent of the latter,
  • The elements likely to identify the person implicated by an alert cannot be disclosed,
  • The person concerned by an alert is informed by the referent as soon as the data concerning him is recorded.

The author of the deposition will be informed without delay of the receipt of his alert and of the foreseeable time required to examine his admissibility.

Both the person reporting a problem and the person concerned by this report will have the right to access, oppose and rectify their personal data included in the report.

However, the person named in the statement does not have the right to know the identity of the person who reported the problem or of a third party, unless these persons have given their consent.

Data collected that does not fall within the scope of the alert will be immediately destroyed.

When the alert procedure is not followed by a disciplinary or legal procedure, the data relating to this alert will be destroyed or archived after anonymization within two months of the closing of the verification operations carried out by the receiver of the report.