Our position

KPMG's position is that bribery and corruption are unethical and unacceptable and are inconsistent with our values and our Global Code of Conduct.

In support of this position, KPMG International has an extensive anti-bribery and corruption program. This includes detailed policies applicable to all member firms and their personnel, as well as training, compliance procedures and an international whistle blowing hotline.

This program represents the baseline for all KPMG member firms. In addition, in many jurisdictions around the world, KPMG member firms supplement this program with additional elements suited to their own home market, such as local hotlines.

KPMG's values and Global Code of Conduct

The KPMG values are at the heart of the Global Code of Conduct, which defines the standards of ethical conduct required of every KPMG partner and employee.

Our values define how KPMG member firms go about their work. The key value, underpinning all others, is that member firms and their people act with integrity - constantly striving to uphold the highest professional standards, provide sound advice, and rigorously maintain their independence.

Specifically in relation to anti-bribery and corruption, the Code commits all KPMG professionals to:

• Act lawfully, ethically and in the public interest;
• Prohibit bribery and corruption by KPMG people;
• Not tolerate illegal or unethical behavior by clients, suppliers or by public officials; and
• Follow high standards of ethical conduct around the world, including aspiring to the ten principles of the UN Global Compact (including anti-bribery).

These commitments reflect KPMG International's position as a signatory of the UN Global Compact since 2002, as well as being a signatory of the World Economic Forum's Partnering Against Corruption – Principles for Countering Bribery.

Member firms are required to adopt or adapt the Global Code of Conduct and communicate it to their people.

Our policies

KPMG International has policies that all member firms are required to adopt concerning:

• Anti-bribery;
• Compliance with laws, regulations and professional standards;
• Requirements to report, and consult in relation to, suspected wrongdoing by KPMG firms or personnel, clients or third parties;
• Facilitation payments;
• Gifts and entertainment;
• Political donations;
• Charitable donations and sponsorships;
• Insider trading;
• Arrangements with suppliers and other third parties, and internal accounting controls.

Our training

KPMG member firms are required to provide anti-bribery and corruption training to their people.

Training on anti-bribery and corruption is included within KPMG International's "Acting with Integrity" course, which also includes modules on areas such as compliance with laws, regulations and professional standards and the Global Code of Conduct.

The training is required to be completed by client facing personnel at a minimum of once every two years, with new hires completing such training within three months of joining a KPMG member firm. In addition, certain non-client facing personnel who work in finance, procurement, or the sales and marketing departments are also required to participate in anti-bribery training tailored to these groups.

Our compliance programs

KPMG International has an integrated monitoring program that covers all member firms to assess the relevance, adequacy and effective operation of key quality control policies and procedures. This monitoring addresses both engagement delivery and certain KPMG International policies and procedures. The results and lessons from the programs are communicated within each member firm and the overall findings from these programs are considered at regional and global levels.

Two cross-functional programs, the Risk Compliance Program (RCP) and the Global Compliance Review program (GCR) monitor compliance with certain KPMG International policies (including, using a risk-based approach, those relating to anti-bribery and corruption) at a member firm level.

Our whistle blowing program(s)

To facilitate the reporting of potential or suspected violations of KPMG policy or applicable laws, regulations or professional standards, including those relating to anti-bribery, KPMG International has a hotline available for KPMG personnel, clients, and other parties to confidentially report concerns they have relating to certain areas of activity by KPMG International itself, those who work for KPMG International, or the senior leadership of a KPMG member firm.

In many cases, member firms around the world also have their own hotlines to facilitate reporting of concerns relating to illegal and unethical acts.