The Whistle-blowing Hotline enables KPMG personnel, clients, and other third parties (such as suppliers, contractors, sub-contractors, external consultants, alliance partners, or other third-party resources) to confidentially report concerns they have relating to certain activities by any KPMG International entity, as well as the activities of KPMG firms or KPMG personnel, including activities by KPMG in Ukraine. Further information is given below on when and how to use the Hotline, as well as how your report will be handled.
When to use the Hotline:
Examples of areas of concern about which you can make a report:
- accounting
- internal accounting controls
- auditing
- banking crime
- financial crime
- bribery, corruption, money laundering, fraud, or other illegal acts.
We specifically encourage reporting relevant issues using this Hotline if:
- such matters relate to KPMG in Ukraine or its employees
- such matters concern the senior leadership of KPMG in Ukraine.
Complaints
The International Hotline may be used if your report relates to the aforementioned areas of activity by KPMG International, KPMG in Ukraine operations, or KPMG senior leadership (e.g. where you believe that either KPMG personnel or a report issued by such does not comply with professional, regulatory, or legal obligations).
The Whistle-blowing Hotline should not be used to raise formal complaints relating to the quality of KPMG services. Under these circumstances, the standard complaints procedures and/or engagement letters should be used.
How to make a report
There are several ways to contact the Hotline:
- By accessing the Web-based reporting system at www.clearviewconnects.com
- Choose KPMG International if your report relates to relevant areas of activity by KPMG International, KPMG in Ukraine operations, or the senior leadership of KPMG in Ukraine. - By calling the toll-free number 0800 801 527 (available 24 hours a day, seven days a week).
Both the online service and telephone line are available 24 hours a day, seven days a week. All reports, regardless of how they are submitted, are handled confidentially (to the extent permitted by law) and in accordance with KPMG member firms’ requirements for handling and investigating reports received.
Given the measures that are in place to ensure report confidentiality and the details of individuals making reports, we encourage you to give your name and contact details when making your 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.
Exceptions only 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 entirely anonymously using either the website or a telephone options available then you will receive a password which will enable you to access the “ClearView Connects” case management system. This will enable us to communicate directly with you while preserving anonymity. If you forget or lose your password, then you will have to submit a new report in order to regain access to the system. In such an event, it would be helpful if you could refer to the previously submitted report to enable us to make the appropriate connections.
For more information, please refer to the KPMG International hotline.
What will happen to your report
If your report concerns KPMG in Ukraine, it will be reviewed by the Ombudsman for KPMG in Ukraine and a member of Quality and Risk Management team in order to determine the investigative action plan.
If your report concerns a member of the Quality & Risk Management team, then your report will be referred solely to the Ombudsman.
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. In any case, your report will be subject to appropriate confidentiality requirements and a non-retaliation policy.
Confidentiality
KPMG International works with Canada-based Mitratech (formerly ClearView Strategic Partners), a third-party administrator of telephone and web-based hotline services, in order to operate the KPMG International hotline. Using an external provider ensures confidentiality for anyone filing a report and anonymity for those who choose to remain anonymous.
Nonetheless, you should also be aware that it may be necessary for us to advise others regarding the substance of your report so as to conduct an appropriate investigation into matters you have raised. As such, your identity may become apparent to such persons and you should consider this potential situation prior to submitting your report.