NOTE: Many of the links in the FAQs below require access to KPMG LLP's Intranet and are only accessible to KPMG partners and employees.
Although you may not know for sure if there has been misconduct or unethical behavior by someone in the firm, or by a client, contractor, vendor, or another external party associated with the firm, you are obligated to raise your concerns regarding potential violations of law, as well as KPMG's standards or policies. You may use any one of the firm's normal Channels of Communication noted in KPMG's Code of Conduct, or the Ethics & Compliance Hotline which allows you to raise your concerns anonymously.
Failing to report known or suspected violations of laws, or our standards, is a violation of the firm's Code of Conduct. Those who violate the firm's standards, regardless of title or tenure, may be subject to disciplinary action.
You should report any concern you may have regarding potential violations of law, regulation, or the firm's Code of Conduct, including - but not limited to - concerns in any of the following categories:
No. KPMG's Hotline is not a 911 or Emergency Service. Do not use this site to report events presenting an immediate threat to life or property. Reports submitted to the Hotline may not receive an immediate response. If you require emergency assistance, please dial 911 or contact your local authorities.
Malicious reporting, or knowingly filing a false report, is a violation of the firm's Values, which underpin our Code of Conduct. Those who violate KPMG's standards, regardless of title or tenure, may be subject to disciplinary action.
Code of Conduct, which provides our values and standards, is available here for review and download to PDF.
Return to Top - Back to Main PageThe Firm offers several Channels of Communication for reporting potential misconduct. Although you should choose the channel you feel most comfortable with, resources closest to the situation are often in a better position to resolve an issue. This usually means your People Management Leader (PML) or Senior People Management Leader (SPML).
Depending on the issue, you may wish to consider other channels of communication. For certain client, engagement, or professional practice-related concerns, consultation with others may be required by firm policy. However, even if consultation is not required, you should feel comfortable seeking advice from or reporting a concern to:
For human-resource related concerns, including harassment, discrimination, and issues involving individual behavior or your work environment consult with Corporate Affairs: Employment and Ethics.
For questions related to legal matters, including contracts or disputes with external parties, or litigation or a government investigation, firm guidance requires you to contact the Office of General Counsel.
For general assistance, questions, or advice related to KPMG's Code of Conduct, you may contact the firm's Ethics and Compliance group at us-eandc@kpmg.com or 1-800-KPMG-HELP, "Option 3" or KPMG partners and employees may also access the Ethics and Compliance portal page.
For any question that you feel uncomfortable raising to the resources noted above, you may contact the firm's Ethics and Compliance Hotline at www.kpmgethics.com or 1-877-576-4033.
KPMG's Ombudsman serves as an additional channel of communication for reports of potential issues involving U.S. Securities and Exchange Commission audit clients and their foreign operations.
To contact the Ombudsman directly, call 212-909-5100 or email us-ombudsman@kpmg.com. For more information about the firm's Ombudsman, KPMG personnel may visit the Ombudsman portal page.
Return to Top - Back to Main PageThe Firm's Ethics and Compliance Hotline enables anyone with a concern to report possible illegal, unethical, or improper conduct. All reports are handled confidentially, subject to limits imposed by the law and professional standards, and the need to conduct a thorough investigation, if warranted, or to take other appropriate action. You have the option to give your name, or to remain anonymous.
The Hotline offers both a toll-free telephone number option - 1-877-576-4033 and a Web site option - www.kpmgethics.com - for filing reports. The Hotline is available to all firm personnel, as well as clients, contractors, vendors, and others in a business relationship with KPMG, including other member firms whose partners and employees may be working with the U.S. firm on engagements with U.S.-based clients.
After you file your report, you will be given a unique report key and asked to choose a password. The key and password will allow you to access your report at a later time.
Click here for instructions on dialing the Hotline from outside of the U.S. and Canada. Click here for a quick reference card on How to File a Hotline Report.
KPMG has contracted with EthicsPoint, an external administrator of telephone and Web-based hotline services, to operate the firm's Hotline. Using an external provider helps to provide confidentiality for anyone filing a report, and anonymity for those who choose to remain anonymous. EthicsPoint does not log or identify callers, or generate internal connection logs of computer IP addresses. EthicsPoint also provides access to our Hotline 24 hours a day, seven days a week.
You may file a report in any language; however, the Web-based questions appear in English. Telephone reports may require the use of a third-party translator, who will assist you and the Hotline operator during your call.
Click here for instructions on dialing the Hotline from outside of the U.S. and Canada. Click here for a quick reference card on How to File a Hotline Report.
The same information is collected whether you file a report via the Hotline Web Site or via the Hotline Call Center. The only difference is that the Call Center utilizes Intake Specialists who ask questions and document your concern, while the Web site provides a written questionnaire for you to fill out personally. Also note that if information is initially filed via the Call Center, you can supplement the report using the Hotline Website.
If you file a Hotline report by phone, the intake specialist will summarize the information you provide and will read the case summary back to you. You will be asked to confirm the accuracy of what has been captured and to change or clarify any aspect of the report. You will be asked for permission to file the report before it is entered into the firm's case management database. If you do not give permission to file the report, or you end the call prior to the completion of these procedures, the report is not filed.
If you file a report via the Web, it is your responsibility to review your online responses before submitting the report. You will need to click the "Submit Report" button to complete your report.
The Hotline allows anonymous "Web chats" between reporters and the investigation team if additional information is necessary, and enables you to receive notice upon the conclusion of an investigation. If you make a report anonymously, it is important to provide detailed information and to check the report regularly, using your report key and password, for information requests from the investigation team.
Although KPMG makes every effort to thoroughly investigate and resolve all good faith reports, there are cases where an anonymous reporter does not provide enough information for an investigation to be performed. In a small number of cases, not providing a name or other identifying information (such as the engagement in question or the office where you work) may prohibit the firm from completing its investigation. Under these circumstances, the matter is considered 'abandoned' because it cannot be investigated. This underscores how important it is for reporters who choose to file their concerns anonymously to check the report regularly, using your report key and password, for information requests from the investigation team.
Finally, if you report anonymously, it is not possible for you to be monitored for potential acts of retaliation.
When reporting via the Ethics and Compliance Hotline, whether via the Web or the phone, you may choose to identify yourself, which often facilitates the firm's ability to fully address your report. KPMG does have a policy of confidentiality, and will protect your identity subject to limits imposed by the law and professional standards, and the need to conduct a thorough investigation, if warranted, or to take other appropriate action.
You will be asked to select the type of report from the list below:
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You will then be asked a series of questions, including:
At the end of your report, you will be asked to choose a password for the report (no other person, including the third party hotline provider, will be provided with your password and if it is lost neither the firm nor the third party hotline provider can reset it or email it to you).
You have a responsibility to give as much information as possible to enable the firm to fully investigate a report. The time it takes to file a report will vary by person and the nature of the concern, but please set aside a minimum of 15-30 minutes.
Intake specialists are employed by the external hotline provider; they are not KPMG personnel and cannot answer questions on the investigation process or KPMG policies and procedures.
KPMG prohibits retaliation against anyone who, in good faith, reports a concern or participates in an investigation, even if the allegation ultimately is not substantiated. You are encouraged to seek advice or report concerns without fear of retaliation.
The firm also has a program designed to protect identified reporters. This program monitors employment status, performance evaluations and metrics, and chargeability, and follows up when necessary to determine whether an individual may have been subject to retaliation.
The firm's policy against retaliation does not mean that you can exempt yourself from the consequences of your own improper conduct by self-reporting. KPMG does, however, encourage self-reporting and, depending on the specific circumstances, may treat self-reporting as a mitigating factor when assessing disciplinary measures in response to improper conduct.
Return to Top - Back to Main PageUsually, KPMG will post an initial response to a new report within 3-5 business days of the report's filing date. It is important to check the report regularly, using your report key and password, for information requests from the investigation team.
The Chief Compliance Officer receives notification from the external hotline provider that a new report has been filed, and determines who should investigate the report. Depending on the nature of the report, the investigation may be assigned to the Ethics and Compliance Group, Human Resources, the Ombudsman or the Office of General Counsel. When appropriate, additional resources, such as Firmwide Security, Risk Management, or outside advisors may be used. The Chief Compliance Officer oversees the investigation of all personnel compliance investigations.
An investigation may include interviews and requests for documentation. Interviews may be in person, over the phone or through an online "web chat." The questions asked will vary based on the nature of the matter being investigated, but are likely to cover the 'who, what, when, where, why' of the situation and your knowledge of it. It is important that you provide accurate and truthful information to the investigation team. Failure to cooperate or lying during an investigation is grounds for discipline, up to and including termination.
The investigation team adheres to the firm's policy of confidentiality and Non-Retaliation Policy.
You can access the original report to provide more information or to check on its status by calling the Hotline (1-877-576-4033) or by logging into the Web site (http://www.kpmgethics.com/) and using your report key and password.
Investigation teams work as efficiently as possible to review and resolve matters. Each investigation is different and the length of time needed to resolve matters varies.
At the conclusion of a case, a notification is posted to the hotline report, which you can access by calling the Hotline or logging into the Web site and using your report key and password. The specific outcome of investigations and actions taken are confidential.
When a report is substantiated, it is referred to functional or departmental leadership to determine appropriate disciplinary action. The case manager or investigation team may make recommendations regarding discipline, to ensure that similar outcomes are treated consistently across the pool of investigations, but ultimately, functional or departmental leaders decide on disciplinary action.
Neither KPMG nor the external Hotline provider can provide you with or reset your report key or password, so safeguarding this information is important. If you lose your report key or password, you will need to file a new report and reference your previously filed report (noting the nature of the concern and the approximate date filed so that we can accurately identify the previously filed report).
Contact the Hotline or the Ethics and Compliance Group (1-800-KPMG-HELP, Option 3 or us-eandc@kpmg.com) if you feel you have been subjected to retaliation. Partners or employees found to have engaged in retaliatory conduct will be subject to discipline.
Every good faith report of misconduct made through the Hotline is investigated thoroughly. Information on the types of issues raised through the Hotline and their resolutions may be found in publications posted on the Ethics and Compliance portal page.
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