Ethics & Compliance Hotline

Welcome

Answers to Your Questions about KPMG's Ethics and Compliance Hotline

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.

What/Why to Report

Where to Report

How to File a Hotline Report

After You File a Hotline Report

What/Why to Report

Q. What should I do if I suspect, observe, or hear about potentially illegal, unethical, or improper conduct?

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, 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.

Q. What types of potentially illegal, unethical, or improper conduct should I report?

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:

  • Accounting, Auditing and Financial Reporting (Firm Record Keeping)
    • Improper recording of time, recording of expenses, use of the firm credit card, billing to clients, or other issues involving the records of the firm.
  • Business Integrity
    • Concerns involving conflicts of interest, improper gifts and entertainment, intimidation or coercion, management / leadership tone, political activities or other integrity issues
  • Client/External Party Conduct
    • Known or suspected illegal or inappropriate acts by KPMG clients, vendors, contractors or other external parties (Although it is not your role to search proactively for potential misconduct by clients beyond what is required by our professional responsibilities, if behavior comes to your attention or you observe activities at a client that are potentially illegal or may raise ethical concerns, you must raise your concerns so they can be fully addressed.)
  • Diversity, Equal Opportunity & Workspace Respect
    • Concerns involving harassment and discrimination.
  • Environment, Health & Safety
    • Personal safety, physical security, threats or acts of violence, substance abuse or environmental concerns. (If you require emergency assistance, please dial 911 or contact your local authorities.)
  • Firm/Client Assets, Resources and Data
    • Concerns involving theft or misuse of client or firm assets (including laptops and PDAs), inappropriate use of email, Internet or other technology resources, improper use of the firm's logo or intellectual property, or loss, theft, misdirection or inappropriate disclosure of firm or client private, proprietary or confidential information
  • Human Relations, Administration & Compensation
    • Employment related concerns including performance management, improper relationships, insubordination, lack of professionalism or other human resource policy or procedure related concerns
  • Potential Violation of DPA – Related Policies
    • Concern that could be a violation of the firm's Deferred Prosecution Agreement
  • Potential Violation of Law
    • Concerns that could be potential illegal conduct
  • Professional Practice
    • Concerns related to the conduct of any audit, tax or advisory engagement or any aspect of the provision of services to firm clients that could be in violation of firm or professional standards
  • Retaliation
    • Conduct regarding actions taken against a reporter or other participant in a personnel compliance investigation (either overt or subtle) as a result of reporting potential misconduct in good faith or participating in an investigation.
  • Ask a Question/Other
    • Request for guidance or information, or to report a concern that does not fit into any of the categories listed above

Q. Should I use the Hotline to report immediate threats to person or property?

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.

Q. What if someone uses the Hotline to make a malicious or false report?

Malicious reporting, or knowingly filing a false report, is a violation of the firm's core values, which underpin our Code of Conduct. Those who violate KPMG's standards, regardless of title or tenure, may be subject to disciplinary action.

Q. Where can I find KPMG's Code of Conduct?

KPMG's Code of Conduct, which provides our core values and standards, is available internally on the Ethics & Compliance Resource Center Web site in pdf form. Externally, a pdf copy of KPMG's Code of Conduct is also available.

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Where to Report

Q. If I have concerns or questions, where can I go for help?

The 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:

  • Your engagement partner(s)
  • Your Practice Leader or Office Managing Partner
  • A Professional Practice or Risk Management Partner
  • An Audit Quality and Professional Practice Partner
  • Washington National Tax
  • The firm's Ombudsman or Chief Compliance Officer
  • Firm leadership, including the Chairman, Deputy Chairman, and board members

For human-resource related concerns, including harassment, discrimination, and issues involving individual behavior or your work environment, your local or regional human resource professional may be an additional resource.

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 Resource Center.

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.

Q. What is the role of KPMG's Ombudsman, and when is appropriate for me to reach out to him?

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 page on US Portal.

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How to File a Hotline Report

Q. What is the Ethics and Compliance Hotline and how do I file a report?

The 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.

Q. Who operates KPMG's Ethics and Compliance Hotline?

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.

Q. May I file a report in a language other than English?

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.

Q. Is there any difference between filing a report via the Hotline Web Site and filing a report via the Hotline Call Center?

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.

Q. What happens if I choose to remain anonymous?

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.

Q. What if I choose to be identified?

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.

Q. What information will I need to provide when I am ready to make a report?

You will be asked to select the type of report from the list below:

  • Accounting, Auditing & Financial Reporting (Firm Record Keeping)
  • Business Integrity
  • Client / External Party Conduct
  • Diversity, Equal Opportunity & Workspace Respect
  • Environment, Health & Safety
  • Firm/Client Assets, Resources & Data
  • Human Relations, Administration & Compensation
  • Potential Violation of DPA (Deferred Prosecution Agreement) – Related Policies
  • Potential Violation of Law
  • Professional Practice
  • Retaliation
  • Ask a Question / Other

You will then be asked a series of questions, including:

  • The location where the incident occurred
  • Whether you wish to remain anonymous
  • Your name, phone number, E-mail address and best time for communication with you should you want KPMG to know your identity
  • Your relationship to KPMG
  • The identity of the person(s) engaged in this behavior
  • A description of the behavior/situation, including any details that could be helpful in the investigation and resolution of this matter
  • When the behavior occurred/began
  • How you became aware of the behavior
  • Whether you or anyone else previously reported the behavior
  • A list of any other person(s) who may be aware of the issue
  • Any documents or files that support your report
  • Whether you would be willing to participate in a confidential telephone call or web chat with someone from KPMG's investigation team to provide additional details that may be helpful for the investigation
  • Whether you are aware that KPMG has a policy of non-retaliation for good faith reporting and a retaliation monitoring program to help prevent retaliation against those who raise their hand
  • How you learned about the Hotline

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).

Q. How long will it take for me to file my report?

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.

Q. The Intake Specialist at the Hotline Call Center says he/she can't answer my questions about the investigation process or KPMG policies/procedures. Why not?

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.

Q. What does the firm do to protect me from retaliation if I file a report?

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.

Q. Do I get 'credit' if I self-report my own improper conduct?

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.

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After You File a Hotline Report

Q. When can I expect a response to my Hotline report?

Usually, 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.

Q. Who receives the reports made to the Ethics and Compliance Hotline and what happens next?

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.

Q. How is the report investigated?

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 policies.

Q. What if I remember something important about an incident after I have filed a report or want to check the status of my report?

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.

Q. How long will the investigation take?

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.

Q. Will I be notified when the investigation is over?

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.

Q. What happens when an investigation substantiates a report?

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.

Q. What do I do if I forget my report key or password?

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).

Q. What do I do if I believe I have been subject to retaliation?

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.

Q. How effective is the Hotline in resolving issues?

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 Resource Center.

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