Kumkum, here is the translated text. I have aggressively stripped out the clumsy literal translations and upgraded the vocabulary to match the global compliance and governance standards of Big Four firms.
KPMG Ethics and Compliance Hotline
The KPMG Ethics and Compliance Hotline is a channel that enables KPMG partners, employees, clients, and other relevant stakeholders to confidentially report various compliance concerns regarding KPMG International, its personnel, or the senior management of a KPMG member firm. Detailed information on when and how to use the Ethics and Compliance Hotline, as well as how your report will be handled, can be found below.
Submit a Report
Website: www.clearviewconnects.com
Phone: Call the Ethics and Compliance Hotline number (Available 24/7)
Mail: Clearview Connects™ P.O. Box 11017 Toronto, Ontario M1E 1N0 Canada
When should the KPMG Ethics and Compliance Hotline be used?
This Hotline should strictly be used to report concerns related to the following:
Accounting
Internal accounting controls
Independent auditing
Banking crimes
Financial crimes
Anti-bribery (including matters related to a client of a KPMG member firm, provided it impacts KPMG)
The Ethics and Compliance Hotline may also be utilized in situations where there is a reasonable belief that the personnel of a KPMG member firm, or the reports issued by them, fail to comply with professional, regulatory, or legal obligations. We specifically request that issues be escalated to the Ethics and Compliance Hotline under the following circumstances:
If the matter concerns KPMG International ("KPMGI") or its personnel, or
If the matter concerns the senior management of the relevant member firm.
Reporting through the Ethics and Compliance Hotline is strictly voluntary; individuals choosing not to use this channel will not face any adverse consequences.
Malicious use of the Ethics and Compliance Hotline may result in disciplinary action against the individual responsible. However, no retaliatory actions will be taken against users who submit reports in good faith.
In addition to the Ethics and Compliance Hotline, many KPMG member firms have their own formal reporting procedures, details of which are available on their respective websites or within audit engagement contracts. If your report concerns one of our member firms, please review our national hotline list below before using the KPMG Ethics and Compliance Hotline to determine if a more appropriate reporting channel exists.
Due to regulatory requirements, the KPMG International hotline is not currently operational in France.
How to Submit a Report
The Hotline offers three distinct methods for reporting compliance concerns:
Calling the toll-free number
Submitting a report online at www.clearviewconnects.com (select KPMG International)
Mailing to the address provided above.
The website and telephone options are available 24/7 and utilize the same format for information gathering. All reports submitted via the website, mail, or phone will be kept confidential to the fullest extent permitted by law and in accordance with KPMGI’s need to investigate the reported matter.
As we implement strict measures to protect the confidentiality of reports and the individuals submitting them, we encourage you to provide your name and contact information without concern. Your identity will be kept confidential throughout all stages of the process and will never be disclosed to the subjects of your report or to third parties. Exceptions to this include circumstances where information must be shared with individuals involved in investigating the matter, situations requiring disclosure in subsequent legal proceedings, and instances where competent authorities request access to such information.
However, if you wish for a report submitted via the website or phone to remain anonymous, you will receive a password granting you access to the "Clearview Connects" case management system. Using this password, you will be able to communicate with us directly without revealing your identity. If you forget your password, you must submit a new report to regain access to the system. In such an event, referencing your previously submitted report will facilitate the process and ensure we can establish the correct connection.
How Your Report Will Be Handled
The KPMG International Global Compliance Officer will review your report and determine the initial steps to be taken. (If your report involves a member of Global Quality & Risk Management [“GQ&RM”], you have the option to route your report directly to the KPMG International Office of the General Counsel).
In our experience, many issues should typically be reported through the member firm's internal channels and subsequently investigated and resolved by that respective firm. If we are able to communicate with you (either through the Clearview system or directly), we will notify you if the matter has been referred to a specific individual within the member firm. If you are a KPMGI or member firm employee, we will ensure that a robust non-retaliation policy is enforced regarding such reports; if no such policy exists, we will mandate its implementation.
If it is inappropriate for the member firm to investigate the matter independently (for example, in cases involving the firm's senior management), the investigation will be conducted under the oversight of KPMGI.
Confidentiality
KPMGI has partnered with Clearview Strategic Partners, a Canada-based provider of telephone and web-based reporting services, to operate this hotline. Utilizing a third-party service provider ensures that the identity of anyone submitting a report is protected and that individuals wishing to withhold their names can remain entirely anonymous.
Please note, however, that in order to properly investigate a disclosure, we may need to inform others about the subject of your report. As your identity may become apparent during the natural course of an investigation, please factor this into your decision before submitting a report.
ClearView Connects™ is a registered trademark of ClearView Strategic Partners Inc.
Strategic Notes:
"İhbar" Translation: I deliberately avoided translating "ihbar" as "informant" or "whistleblowing" wherever possible, opting instead for "Submit a Report," "Report," or "Disclosure." "Informant" has criminal connotations, and "whistleblowing" can sometimes carry a hostile tone in modern corporate HR. "Reporting a compliance concern" is the polished, standard C-suite language.
"Kısas Yasağı Politikası": The literal translation is terrible. In global HR and compliance, this is definitively known as a "Non-Retaliation Policy." * Active vs. Passive: I tightened up the sentence structures. Legal Turkish relies heavily on passive, trailing sentences. Good legal English relies on active, definitive statements.