KPMG’s Speak Up Hotline - FAQs

What is the purpose of KPMG’s Speak Up Hotline?

The Speak Up Hotline provides all individuals (both internal and external) with a confidential opportunity to raise concerns about suspected wrongdoings, dangers or unethical conduct (also known as whistleblowing), including concerns that KPMG or our people have failed to meet professional standards.

Concerns which relate to matters covered by the Public Interest Disclosures Act 1998 (“PIDA”) may also be reported via the Speak Up Hotline. PIDA protects whistleblowers from detrimental treatment by their employer for disclosing certain information in the public interest, such as a criminal offence being committed or where the health and safety of an individual has been or is likely to be endangered.

Why should you raise a concern?

It is vital that suspected wrongdoings or dangers are identified as soon as possible to improve accountability and to safeguard our people, clients, audited entities, the wider public interest, and the firm’s reputation and integrity. Ultimately, this will help to maintain the trust placed in us when conducting our work.

When should you raise a concern?

As early as possible. It is important that any concerns are identified and addressed as soon as the problem arises in order to avoid escalation. Delays might compromise our ability to deal with the allegation appropriately.

What matters can you report to the Speak Up Hotline?

Concerns can be reported to our Speak Up Hotline that relate to a matter covered by PIDA, or that the firm or our people have failed to meet professional standards.

Reports covered by PIDA would include:

• criminal activity
• miscarriages of justice
• danger to health and safety
• damage to the environment
• bribery (such as giving or receiving any gift or reward as a bribe) contrary to our Anti-Bribery and Corruption Policy
• facilitating tax evasion contrary to our Corporate Criminal Offences Policy
• financial fraud or mismanagement
• money laundering
• breach of competition law
• modern slavery

How can you make Speak Up report?

You can access our Speak Up Hotline here, or if you would prefer not to make an online report you can:

• Call a toll-free number 0808 101 5341 (call from mobile phones will be charged)
• Mail to Clearview Connects, P.O. Box 11017 Toronto, Ontario, M1E 1NO, Canada.

Alternatively, you may use the KPMG International hotline if you are concerned that the UK firm’s channels are not appropriate for your concern. Details on the KPMG International hotline can be found here.

Who operates the Speak Up Hotline?

The Speak Up Hotline is hosted by an independent external organisation called ClearView Strategic Partners who administrate and operate telephone and web-based hotline services via its ClearView Connects platform.

Can you make a report in any language?

We require reports to be made in English.

When can you contact the Speak Up Hotline?

The Speak Up Hotline is available 24 hours a day, 7 days a week, 365 days a year.

What are the usual timescales for responding to a complaint and when can I expect to hear back?

Concerns raised through the Speak Up Hotline will be dealt with as quickly as possible and reporters will receive regular updates from the Ombudsman as their case progresses.

Can you remain anonymous when making a report?

Yes, you can make anonymous reports.

Reporters who make an online report will be given a password so that they can access the ClearView Connects case management system, to allow the firm to contact the reporter whilst preserving their anonymity. If you chose to provide your name and it is necessary for anyone investigating the concern to know your identity, it will be discussed with you first.

There are some very limited circumstances in which confidentiality cannot be maintained, including: if a disclosure is required by law, if there is evidence that a crime has been or is about to be committed, or if the reported information leads to a suspicion of money laundering. If this is the case, the reporter will be informed as soon as possible.

What if your concern relates to someone on the Executive Committee or Board?

You are still able to report a concern, regardless of the seniority or position of the individual involved.

In the scenario where your complaint does relate to someone on the Executive Committee or Board, the firm’s Ethics Partner, Head of Conduct and Professional Standards or General Counsel will be responsible for looking into the concern and may instruct external counsel to independently investigate the matter if necessary.

Can you report concerns to external bodies instead?

KPMG encourages everyone to report concerns through our Speak Up Hotline wherever possible. However, in certain circumstances, it may be appropriate to report concerns to an external body, such as to a regulator (for example, to the Financial Conduct Authority (“FCA”), the Financial Reporting Council (“FRC”), or the Solicitors Regulation Authority (“SRA”)).

Where can you go for advice on speaking up?

Protect, an independent whistleblowing charity, operates a confidential helpline and offers advice and support on speaking up (details of which can be found here). Protect will not investigate concerns raised, but Protect will provide advice on how best to raise the concern you have.

Who oversees KPMG’s Speak Up Hotline?

The operation of the Speak Up Hotline is overseen by an independent Ombudsman (the “Ombudsman”) who reviews cases and reports to the KPMG Board on the effectiveness of the arrangements.

Our Ethics Partner has ultimately accountability for the operation of the Speak Up Hotline.

How does KPMG investigate concerns reported to the Speak Up Hotline?

The Ombudsman will carry out an initial assessment to determine the scope of any investigation in conjunction with KPMG’s Speak Up Case Managers. The reporter will be informed of the outcome of that initial assessment, and they may be asked some additional questions or asked to attend meetings to provide further information (unless they wish to remain anonymous).

Where the report falls into the scope of the Speak Up hotline, an investigation is undertaken with oversight from the Ombudsman. The investigator(s) may make recommendations for change to minimise the risk of future wrongdoing.

Reporters will be informed, as appropriate, of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent specific details of the investigation, or any action taken as a result, being provided.

What happens if somebody that you have made a report about finds out you made the report?

KPMG wants everyone to be able to speak up in a safe environment about conduct or other issues that they believe to be unfair, unethical, discriminatory, illegal, or otherwise reportable. We appreciate that you may be worried about the possible repercussions as a result of raising a concern, however KPMG does not tolerate any retaliation against any individual (internal or external) who reports a complaint.

If a reporter believes they have suffered any detrimental treatment or retaliation for raising a concern through the Speak Up Hotline, they should report this to the Ombudsman (as detailed below) immediately.

Can you get into trouble for making a report which turns out to be unfounded?

KPMG encourages any person to raise a genuine concern, even if that person is mistaken, or their concern turns out to be unfounded, or they do not have any proof of such wrongdoing. However, making an intentionally false accusation or allegation is a serious legal matter.

How can you contact the Ombudsman?

The Ombudsman can be contacted via the Speak Up hotline.