Ethical behaviour

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Our firm

Ethical behaviour

We're committed to acting responsibly and taking accountability for the way we do business.

Empowering our people to speak up

Our success and reputation depends on our people doing the right thing. Our Code of Conduct helps them understand how we do this and underpins everything we do. Built on the foundation of Our Values, it conveys clearly our commitment to acting responsibly and taking accountability for the way we do business.

An important part of this is empowering our people to speak up – not just expecting them to trust us, but actively demonstrating why and how they can trust us. To do this, our focus as a firm is on four areas:

  1. Creating the right environment where people feel able to speak up
  2. Listening when they raise any concerns
  3. Taking action and investigating their concerns appropriately
  4. Protecting them from retaliation when they raise concerns.
86% / of our colleagues feel they know what they need to do to live Our Values in their day to day work* 2020 Global People Survey

*Data based on 7,302 colleague responses to our 2020 Global People Survey

Creating the right environment for people to speak up

We encourage our people to speak up where they have issues or concerns about unethical working practices or where someone isn't living Our Values. We have a number of ways in which our people can speak up, including through our network of Ethics Champions and via our Speak Up Hotline. Our people may, if they wish, report and issue or concern anonymously and we will always seek to maintain confidentiality wherever we are able to do so.

Ethics Champions We have over 120 Ethics Champions across the firm. Anyone can approach any Ethics Champion, no matter their location or capability. As well as helping our people to report or discuss any ethical issues or concerns, they will also help to identify and address any examples of poor ethical practices.
Speak Up Hotline Our Speak Up Hotline is a secure and confidential channel for our colleagues to share what's on their mind. It is monitored by an independent ombudsman who oversees investigations arising from reports received, and reviews and/or makes recommendations with regard to any actions taken by the firm as a result. Colleagues can check-in to see the progress of their report at any time.
Other routes to speaking up To guide our colleagues on the best route for raising concerns, information on all routes for speaking up is available on our internal website. We recognise that speaking up takes courage. We remind our colleagues of the wellbeing support available to them to support them in this process, for example, our independent Employee Assistance Programme, and the health helpline Health at Hand.
Number of Ethics Champions / 123 Year to September 2020
Reports to Speak Up hotline / 57 FY20
Reports to Ethics Champions / 189 FY20

Building and sustaining an ethical culture

Listening when concerns are raised

As important as our people having a responsibility to speak up is our responsibility as a firm to listen. We take this responsibility seriously and provide our people with a number of mechanisms to support our commitment to listening.

Our Ethics Champions are a nationwide network of trusted colleagues who are trained to and will listen without bias or judgement to concerns raised about unethical working practices or where someone isn't living Our Values.

We think it's important to hear from those who have spoken up so they can explain what motivated them to speak up, how they felt during the process and what advice they would give others in a similar situation. This is why, with the permission of those who have spoken up, we tell our people some of their stories through our news channels and training.

Taking action and investigating concerns

When our people speak up, we take action to investigate and address their concerns. Independent reviews of how we take action when concerns are raised, and our speak up processes, have been undertaken in the last year by:

  • Our independent ombudsman, whose role is to oversee the handling of investigations raised through the Speak Up Hotline. Every six months the ombudsman prepares a report on how we have conducted our investigations.
  • Protect, the leading authority on whistleblowing in the UK, who we engage to help us understand what we could improve in our speak up processes to become best-in-class. Protect helps workers to speak up to stop harm and wrongdoing, supports organisations in establishing open and positive whistleblowing cultures, and campaigns for legal and policy reform to better protect whistleblowing. As part of this, Protect performed an independent benchmark of our Speak Up arrangements in February 21 which compared us to industry best-practice in a number of areas.

I am satisfied that investigations are conducted seriously. My questions and comments elicit appropriate responses. I do not consider that there are undue delays in conducting investigations. The information provided appears to me to be sufficient to reach a conclusion.

Independent ombudsman report to our UK Board, April 2021

Protecting those that speak up from retaliation

We are committed to an environment in which our people can speak up and be supported throughout the process without fear of retaliation:

  • We have zero-tolerance of retaliation enshrined in policy, and disciplinary action will be taken against anyone who has retaliated in any way against someone who has raised a concern (up to and including summary dismissal). 
  • As part of our package with Protect, they provide confidential and independent advice directly to any of our people who are concerned about wrongdoing or malpractice at work, and who are unsure about whether or how to raise it. Our people can contact Protect directly at any stage by calling 0800 0557259 or visiting their website.
  • In the event that anyone feels, or believes, that their report isn't being taken seriously, or they don't feel protected, they can also raise this with our ombudsman through the Speak Up Hotline.
74% / of colleagues answered favourably that they felt they could report unethical practices without fear of there being a negative impact on them*. 2020 Global People Survey

*Data based on 7,302 colleague responses to our 2020 Global People Survey

Modern slavery

In March 2018, we introduced our Anti-Slavery & Human Trafficking policy, which applies to all KPMG Individuals. This policy outlines our zero-tolerance stance on modern slavery, the potential sanctions for breach of this policy, and an obligation to report any suspected acts of non-compliance from within the business or supply chain via the Speak Up Hotline (which is publicly available on our website, and therefore available for use by employees within our supply chain). As of 31 December 2020, 0 reports have been made in relation to modern slavery.

Alongside our Anti-Slavery & Human Trafficking policy, KPMG was one of the first organisations to become an accredited Living Wage employer and we are a founding Principal Partner of the Living Wage Foundation. We encourage our suppliers to pay the Living Wage and pursue accreditation. This is an important aspect of our Modern Slavery position and helps to raise the employees of our direct service providers out of working poverty. Similarly, our Equality, Diversity and Inclusion policy promotes a work environment where each person is treated equally irrespective of differing characteristics. We expect our suppliers to share our high standards towards ethical behvaiour.

As part of our Sustainable Procurement strategy, we take a risk-based approach to understanding and monitoring risks of modern slavery in our supply chain. In FY20, we took into consideration: location of operations and prevalence of modern slavery; category risk and vulnerable worker groups; along with the level of spend and whether a contract is in place. Using this approach, we identified 59 high and medium risk suppliers which were sent a modern slavery self-assessment to complete. We engaged with these suppliers to provide information on policies, procedures and training within their own operations, and their supply chain, to identify any gaps or areas of risk. Modern slavery was not identified in any of the responses received. More details on our approach to managing risks of modern slavery in our supply chain can be found in our Modern Slavery Statement.

Measuring the effectiveness of our approach: our commitments for this year

1 Extended review of high-risk suppliers across the lower spend brackets
2 Identify the percentage of KPMG's Third-Party Intelligent Diligence (K3PID) tool checks on key high and medium risk suppliers
3 Identify the percentage of staff that have completed the Modern Slavery training
4 Identify the percentage of key high and medium risk suppliers offered Modern Slavery training

Political and policy engagement

We recognise the importance of engaging with politicians, policy makers and our regulators on issues of relevance to business and society, such as regional growth, Net Zero and the future of work. Whilst at all times maintaining a position of political neutrality, our insights and experience help to strengthen public policy.

Our engagement takes place across a range of forums – from participation in think tank roundtables to holding events at political party conferences – and is focused on areas where we feel that we can make a valuable contribution to the debate. We also help to improve public policy through our involvement in industry-led government forums and trade body committees.

We are committed to ensuring that our political engagement is based on principles of transparency, integrity and accountability and we aim to demonstrate best-practice in conducting political engagement at all levels of government.

As part of this commitment, we have a formal policy in place, which applies to all UK partners and colleagues, to ensure that our engagement is conducted in a manner that demonstrates our firm's commitment to: be a responsible employer; have a positive societal impact; and to support our communities to prosper. This includes guidance on both formal political engagement, as well as voluntary political activity. It’s underpinned by the principles set out in Our Code of Conduct, to act responsibly and in the public interest.

The Future of Towns: tackling a divided vision for the future

We are committed to playing our part in supporting regional growth. To help us do this, we wanted to better understand what the future looks like for our towns. Working alongside the leading cross-party think tank Demos, who conducted extensive public polling and social media analysis on the topic, we facilitated regional business leader focus groups to explore the opportunities and challenges facing towns, as the government looks to ‘Build Back Better’ from the COVID-19 pandemic.

Our research found that towns are split down the middle over their vision for the future, with opposing views on: the prospect of newcomers from cities and other countries; issues related to the ageing population; the need for new housing; the creation of new jobs; and the prioritisation of a sense of community.

Our report, The Future of Towns, provides recommendations for how central government, town leaders, businesses and residents could, and should, work together to tackle this divide. From further economic assessments, to participatory conversation and community buy-in, the aim is simple: to unite people in towns behind a single vision for the future, one that enables them to take advantage of the large-scale investment promised as part of the government’s “levelling-up” agenda. As a large UK employer, we recognise we have a role to play in driving action on these recommendations, which is why we’re engaging with cross-party politicians and policy makers to strengthen public policy in this area, in support of the future revival of the towns we operate in.

Read the report