At KPMG in the UK, our promise of professionalism to each other, our clients, and the capital markets we serve, compels us to align our culture of integrity with words and actions.

By setting high standards for ourselves, our clients and our audited entities, our commitment to upholding KPMG's Values and Our Code of Conduct is clear: there is never a situation when compromising our professional standards is either expected or acceptable. To support our culture of integrity, KPMG has developed a robust ethics program that includes a number of elements, including operating a Whistle-blowing Hotline.

Whistle-blowing Hotline

Our Whistle-blowing Hotline facilitates the reporting of possible illegal, unethical, or improper conduct when the normal channels of communication have proven ineffective or difficult. The Hotline is available to be used by all of our people, as well as clients, audited entities, contractors, suppliers and others in a business relationship with KPMG.

Reasons for raising an issue through our Whistle-blowing Hotline

Whistleblowing is the disclosure of information that relates to suspected wrongdoing or dangers at work.  Concerns can be reported, through this Hotline, that relate to a matter covered by the Public Interest Disclosures Act 1988 (“PIDA”), or that the firm or our people have failed to meet professional standards.

Examples of issues that can be raised (including deliberate concealment of any of the below matters):

1. Reports relating to matters where there is formal legal protection for whistle-blowers under (“PIDA”):

• 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

2. Reports relating to concerns that the firm or our people have failed to meet professional standards, including:

• failure to comply with any legal or professional obligation or regulatory requirements
• breach of our internal policies and procedures
• any conduct which is not consistent with Our firm’s Code of Conduct
• conduct likely to damage our firm’s reputation or financial wellbeing
• any conduct that is likely to undermine the provision of high-quality audits
• any conduct that is likely to undermine the quality of any of our other professional services
• unauthorised disclosure of confidential information
• failure to safeguard personal and sensitive information
• negligence
• maladministration (such as not adhering to procedures or negligence)
• failure to manage conflicts of interest

We encourage reporting of such issues using this Hotline if the matter relates to KPMG in the UK or its partners or employees, and/or concerns senior leadership of KPMG UK.

Complaints about the quality of KPMG services

Please do not raise formal complaints about the quality of KPMG services through the Whistle-blowing Hotline. Our standard complaints procedures as set our here and/or within engagement letters should be used in these instances.

Complaints about other KPMG member firms

If your report relates to a KPMG member firm other than KPMG UK, please contact the relevant member firm directly or use  the KPMG International Hotline

How to make a report

Our Whistle-blowing Hotline offers three ways to report concerns:

• By calling a toll-free number - 0808 101 5341. Please note that calls from mobiles will be charged
• By accessing a web-based reporting system (external link)

By reporting, via surface mail, to the following address:

ClearView ConnectsTM

P.O. Box 11017

Toronto, Ontario

M1E 1N0

Canada

Both the website and the telephone 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 in the UK's requirement to investigate and address the reported conduct.

Reports are confidential, but we encourage giving personal details as this better enables us to investigate your concern.

Where applicable, you can use KPMG’s International hotline — click on this link for more details.

What will happen to your report?

Your report will initially be reviewed by the UK firm's ombudsman and a member of KPMG UK's risk and legal team.  They  will determine the appropriate initial action.

If your report relates to a member of the KPMG risk and legal team then only the ombudsman will receive the report.

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. Whether referred to another KPMG member firm or to KPMG International your report will be subject to appropriate confidentiality and a non-retaliation policy.

Confidentiality

KPMG in the UK is working with Canada-based ClearView Strategic Partners, a third party administrator of telephone and web-based hotline services, to operate the KPMG UK 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 ConnectsTM is a registered trademark of ClearView Strategic Partners Inc.