Our promise to act professionally and in accordance with applicable laws and ethical values towards each other, our clients and the capital markets requires integrity in our words and actions. We are clearly committed to the values set out by KPMG in the form of a Code of Conduct. Questioning applicable laws or our values is unacceptable. To maintain our culture of integrity, KPMG has long maintained a whistleblowing hotline in Germany.
Which reporting centres does KPMG maintain?
In fulfilment of the legal requirements from the
- Act for Better Protection of Whistleblowers (Whistleblower Protection Act, ‘HGSchG’)
and the
- Act on Corporate Due Diligence in Supply Chains (Supply Chain Due Diligence Act, LkSG)
KPMG maintains the reporting channels for whistleblowers described in more detail below. The whistleblowing hotline is designed as an internal reporting office within the meaning of Section 14 of the HGSchG and also fulfils the function of a complaints office within the meaning of Section 8 of the LkSG.
Who can use the whistleblowing hotline?
The whistleblowing hotline can be used by all employees within the meaning of Section 3 (8) HGSchG, but also by clients, subcontractors, suppliers and other third parties, including as a complaints office within the meaning of Section 8 LkSG.
What kind of information can be reported to the whistleblowing hotline?
The whistleblowing hotline enables the reporting of illegal or unethical conduct when other communication channels have proven to be ineffective or inappropriate. In cases where effective internal action can be taken against a violation and the whistleblowers do not have to fear reprisals, reporting to the whistleblowing hotline as an internal reporting centre should be preferred.
The whistleblowing hotline can be used in particular for reporting and disclosing information about violations within the meaning of Section 2 HGSchG. These include, for example, violations that are punishable by fines or other penalties under criminal law, or violations of legal provisions, e.g. those relating to combating money laundering and terrorism, or other violations of legal provisions, e.g. those relating to combating money laundering and terrorism. life or health, the protection of the rights of employees or their representative bodies – are punishable by fines, or other violations of legal provisions, e.g. for combating money laundering and terrorist financing, for the protection of personal data, for auditing companies of public interest or for the accounting of companies that are capital market-oriented.
Furthermore, it is possible to draw attention to human rights or environmental risks as well as violations of human rights or environmental obligations within the meaning of Sections 8 and 9 of the LkSG.
The whistleblowing hotline can also be used to report misconduct by KPMG employees in relation to professional standards or against self-imposed values in the form of the Code of Conduct.
We encourage everyone to raise any concerns they may have regarding KPMG in Germany, its employees or its management. If your concern relates to a KPMG company that is not a subsidiary of KPMG AG Wirtschaftsprüfungsgesellschaft, please contact that KPMG company directly or use the KPMG International Hotline, which can be reached via the details provided at the following link.
How can a report be submitted?
KPMG operates the whistleblowing hotline as an internal reporting centre with the involvement of an external lawyer based in Berlin. The involvement of a person outside the organisation who is bound by professional secrecy guarantees confidentiality for all those who submit a report, anonymity for those who do not wish to disclose their name, and impartiality, as the lawyer is independent and not bound by instructions. The whistleblowing hotline offers the following options for submitting a report:
- By telephone, using the telephone number:
+49 30 31 01 82 15
You can reach solicitor Dr Margarete Gräfin von Galen on the telephone number provided. She is available during regular office hours (9 a.m. to 6 p.m.). Outside these office hours, an answering machine is available to take messages.
- By post or email to the following contact details:
Rechtsanwältin Dr. Margarete Gräfin von Galen
Mommsenstr. 45
10629 Berlin
- Use of a web-based online reporting system *
From here, the report will be made available to solicitor Dr Margarete Gräfin von Galen and – unless the reporting person excludes this option – to a small group of employees in KPMG's Quality & Risk Management department.
What happens to a report?
Every report is processed in accordance with legal requirements (in particular Section 17 HGSchG and Sections 8, 9 LkSG).
The internal reporting office receives each report, confirms receipt, evaluates it, discusses the facts with the whistleblower and decides on the next steps to be taken in terms of clarification and investigation, depending on the violations and/or irregularities reported. This is done in consultation between lawyer Dr Margarete Gräfin von Galen and the employees from the Quality and Risk Management department designated in accordance with Section 15 HGSchG. The internal reporting office determines the follow-up measures in accordance with Section 18 HGSchG.
Lawyer Dr Margarete Gräfin von Galen maintains contact with the whistleblower and informs them of the conclusion of the investigation and the findings.
The content of every report and every reporting person within the scope of the Whistleblower Protection Act is subject to the protection of this Act. Reports are treated as strictly confidential; upon request, the anonymity of a whistleblower is also protected by lawyer Dr Margarete Gräfin von Galen vis-à-vis KPMG employees in the internal reporting office.
Reports that do not concern KPMG in Germany and, for example, another KPMG firm that is a member of the global KPMG organisation of independent member firms will be forwarded to KPMG International. If a report is forwarded to another group company of KPMG AG Wirtschaftsprüfungsgesellschaft or to KPMG International, it is subject to the relevant regulations on confidentiality and protection against retaliation.
KPMG encourages the reporting of violations of laws and ethical principles. Whistleblowers, and employees in particular, need not fear any negative consequences for reporting in good faith within the meaning of Sections 33 and 34 of the HGSchG or for supporting such reporting (Section 36 HGSchG). KPMG Germany's Code of Conduct prohibits sanctions against anyone who reports a possible violation in good faith or participates in an investigation, even if sufficient evidence cannot be provided to substantiate the concerns raised.
* KPMG in Germany cooperates with Clear View Strategic Partners** in Canada, an independent provider of web-based hotline services. Please note the information in the reporting system, particularly with regard to the options for maintaining anonymity.
** Clear View ConnectsTM is a registered trademark of ClearView Strategic Partners Inc.
Rules of procedure
Establishment and operation of a reporting office in accordance with the Whistleblower Protection Act and the organization of a complaints procedure in accordance with the Supply Chain Due Diligence Act