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Anti-bribery and corruption Anti-bribery and corruption

Our Global Code of Conduct and our extensive anti-bribery and corruption program are designed to ensure we uphold the highest standards of professional integrity.

Our position

KPMG's position is that bribery and corruption are unethical and unacceptable and are inconsistent with our Values and our Global Code of Conduct.

In support of this position, KPMG International has an extensive anti-bribery and corruption program. This includes detailed policies applicable to all KPMG firms and their personnel, as well as training, compliance procedures and an international whistle-blowing hotline.

This program represents the baseline for all KPMG firms. In addition, in many jurisdictions around the world, KPMG firms supplement this program with additional elements suited to their own home market, such as local hotlines.

KPMG's Values and Global Code of Conduct

Outlined in KPMG’s Global Code of Conduct are the responsibilities all KPMG people have to each other, our clients, and the public. It shows how our Values inspire our greatest aspirations and guide all of our behaviors and actions. It defines what it means to work at and be part of KPMG, as well as our individual and collective responsibilities.

Our Values lie at the heart of the way we do things. To do the right thing, the right way. Always. They drive our daily behaviors, guide our decisions, and shape our character. They form the foundation of a resilient culture ready to meet challenge with integrity, so we never lose sight of our principal responsibility to protect the public interest. And they propel us forward — through our work and the example we set — as we inspire confidence and empower change throughout the world.

Our collective commitments as stated in the Global Code of Conduct, specific to anti-bribery and corruption, include:

  • Act lawfully, ethically and in the public interest;
  • Not tolerate behavior within KPMG, by clients or suppliers, or public officials with whom we deal, that is illegal, unethical or breaches human rights;
  • Not accept or offer bribes, or participate in corrupt practices, and have a zero tolerance for bribery and corruption in any form by any party; and
  • Follow high standards of ethical conduct around the world, including aspiring to the ten principles of the UN Global Compact (including anti-bribery).

These commitments reflect KPMG International's position as a signatory of the UN Global Compact since 2002, as well as being a signatory of the World Economic Forum's Partnering Against Corruption - Principles for Countering Bribery.

KPMG firms are required to adopt the Global Code of Conduct or where the firm utilizes its own local Code, ensure that the local firm Code is consistent with the Global Code of Conduct and communicate it to their people.

Our policies

KPMG International has policies that all KPMG firms are required to adopt concerning:

  • Anti-bribery;
  • Compliance with laws, regulations and professional standards;
  • Requirements to report, and consult in relation to, suspected wrongdoing by KPMG firms or personnel, clients or third parties;
  • Facilitation payments;
  • Inducements, including gifts and entertainment;
  • Political donations;
  • Charitable donations and sponsorships;
  • Insider trading;
  • Arrangements with suppliers and other third parties, and internal accounting controls.

Our training

KPMG firms are required to provide anti-bribery and corruption training to their people.

Training on anti-bribery and corruption is included within KPMG International's "We Do What is Right: Integrity at KPMG" course, which also includes modules on areas such as compliance with laws, regulations and professional standards and the Global Code of Conduct.

The training is required to be completed by client-facing personnel annually, with new hires completing such training within three months of joining a KPMG firm. In addition, certain non-client facing personnel who work in finance, procurement, or the sales and marketing departments are also required to participate in anti-bribery training tailored to these groups.

Our compliance programs

KPMG International has monitoring programs that evaluate KPMG firm compliance with KPMG International key policies and procedures and the relevance, adequacy and effective operation of key quality control policies and procedures. The results and lessons from the programs are communicated within each member firm and the overall findings from these programs are considered at regional and global levels.

Two cross-functional programs, the Risk Compliance Program (RCP) and the Global Compliance Review program (GCR) monitor compliance with certain KPMG International policies (including, using a risk-based approach, those relating to anti-bribery and corruption) at a KPMG firm level.

Our whistle-blowing program(s)

To facilitate the reporting of potential or suspected violations of KPMG policy or applicable laws, regulations or professional standards, including those relating to anti-bribery, KPMG International has a hotline  available for KPMG personnel, clients, and other third parties to confidentially report concerns they have relating to certain areas of activity by any KPMG International entity, activities of KPMG firms or KPMG personnel.

In many cases, KPMG firms around the world also have their own hotlines to facilitate reporting of concerns relating to illegal and unethical acts.

Throughout this webpage, “we”, “KPMG”, “us” and “our” refers to the global organization or to one or more of the member firms of KPMG International Limited (“KPMG International”), each of which is a separate legal entity. KPMG International Limited is a private English company limited by guarantee and does not provide services to clients. Member firms of the KPMG network of independent firms are affiliated with KPMG International. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.

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