Reports made to this Hotline should only be in relation to the following:
- Internal accounting controls;
- Banking crime;
- Financial crime; and
- Anti-bribery (including in relation to a client of a KPMG member firm, in so far as it affects KPMG).
In addition, it can be used for reporting instances where either personnel of one of the member firms of the KPMG network or reports issued by them are felt not to comply with professional, regulatory or legal obligations. In particular we encourage reporting of such issues using this Hotline if:
- it relates to KPMG International (“KPMGI”) itself or its employees; or
- it concerns senior leadership of the relevant member firm.
There is no obligation on an individual to make a report through the Hotline and there are no sanctions that can or will be applied to any individual if they decide not to make a report using the Hotline.
Any abuse of the Hotline may result in action being taken against the perpetrators of the abuse. However, provided users of the system act in good faith, they will not face sanctions against them.
In addition to this Hotline, several of the member firms of the KPMG network have their own formal complaints procedures, details of which can be obtained from the relevant Web sites or engagement letters. If your report relates to one of our member firms, please see our national hotline list below before using the KPMGI Hotline to see if there is another site or email address which better suits your needs.
For regulatory reasons, the KPMG International hotline does not currently operate in France.
For legal reasons, the KPMG International Hotline should not currently be used by members of staff of the KPMG member firms in the Netherlands.
The Hotline offers three ways to report concerns:
- By calling a toll-free number
- By accessing a Web-based reporting system at www.clearviewconnects.com (select KPMG International)
- Reporting via surface mail to the following address:
Clearview Connects ™
P.O. Box 11017
Both the Web site and the phone 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 KPMGI’s requirement to investigate and address the reported conduct.
Given the measures that are in place to ensure the confidentiality of reports and the details of individuals making reports, we encourage you to give your name and contact details when making you report. Your identity will be kept confidential at all stages of the process and will not be disclosed to third parties or individuals who are the subject of your report. The exceptions to this include where it is necessary to disclose information to relevant persons involved in any further investigation of the matter, where disclosure is required for any subsequent judicial proceedings or where access is requested by any regulatory authority. However, if you wish to make your report anonymously using either the Web site facility or a live telephone operator then you will receive a password which will enable you to access the “Clearview Connects” case management system. This will allow us to communicate directly with you while preserving anonymity. If you forget or mislay your password then you will have to submit a new report in order to regain access to the system; in this event it would be helpful if you could refer to the previously submitted report to enable us to make the appropriate connections.
Your report will be reviewed by the KPMG International Global Regulatory Compliance Manager who will determine the appropriate initial action. (If your report concerns a member of Global Quality & Risk Management (“GQ&RM”) then you have the option to refer the report initially to a member of the KPMG International Office of General Counsel.) In our experience many matters should normally be reported through member firm vehicles and investigated and resolved by the relevant member firm. If we can communicate with you (either through the Clearview system or directly) we would normally inform you that we are referring the matter to a named individual in the member firm. If you are an employee of KPMGI or a member firm, we will ensure that either an appropriate non-retaliation policy is in effect covering such reports or one is put in place for the specific instance.
If it is not appropriate for the member firm to investigate the matter itself (for example where it concerns the senior leadership of the firm) then the investigation will be conducted under the auspices of KPMGI.
KPMGI is working with Canada-based Clearview Strategic Partners, a third party administrator of telephone and Web-based hotline services to operate the organization’s 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 Connects™ is a registered trademark of ClearView Strategic Partners Inc.