Independence, integrity, ethics and objectivity
This entails systematic information analysis that enables us to anticipate any conflicts of interest or issues in complying with established rules, standards and policies.
The procedures and policies that underpin our efforts in respect of these principles are set out in our Code of Conduct, Global Marketing Risk Management (GMRM) and Global Quality and Risk Management Manual (GQ&RM Manual).
These documents are derived from the professional requirements and rules established by local legislation, the Federal Accounting Council, the Brazilian Independent Auditors Institute, the National Monetary Council, the Securities Commission, the Secretary for Complementary Social Security and international bodies, such as the Public Company Accounting Oversight Board and the US Securities and Exchange Commission.
The contents of these documents are transmitted to our professionals through our leadership and systematic training on ethics, independence and anti-corruption, as well as on the Intranet.
Annual training on ethics and independence and anti-corruption is mandatory for all partners, managers and other client-facing professionals, including interns at technical functions, as well as administrative leadership. After concluding this training, professionals sign an agreement confirming their understanding and acceptance of KPMG in Brazil's policies and their independence in performing their duties. During the period covered by this report, all professionals required to attend training were trained in Ethics & Independence and 99.44% in Anti-corruption policies.
Mandatory* Professional Attendance at Ethics & Independence and Anti-corruption training G4-SO4
| Ethics and Independence (E&I) | Anti-corruption | |||||
|---|---|---|---|---|---|---|
| 2014 | 2013 | 2012 | 2014 | 2013 | 2012 | |
| Non-management | 2,289 | 2,256 | 2,440 | 2,235 | 2,084 | 2,878 |
| Management | 477 | 460 | 446 | 454 | 390 | 455 |
| Partners | 283 | 279 | 262 | 279 | 227 | 263 |
| Interns | 6 | - | - | 3 | - | - |
| Total professionals | 3,055 | 2,995 | 3,148 | 2,971 | 2,701 | 3,596 |
|
* Ethics & Independence - Professionals required to take training: partners, managers, professionals and client-facing technical staff interns, and administrative function heads. All required professionals attended training. Professionals in the categories above are not required to attend training if they were on secondment or on leave during the relevant year. * Anti-corruption - Under new rules as from August 2013, this training is no longer a requirement for the entire Organisation but only for technical (client-facing) functions and administrative leadership. For this reason, attendance in absolute figures has declined from previous years. Of those required to take training, 99.66% of our professionals attended training from 1 October 2013 to 30 September 2014. After this period, professionals failing to take training are subject to an assessment by our Disciplinary Committee. |
||||||
Global Code of Conduct (G4-56)
Our Global Code of Conduct expresses our commitments to stakeholders and how our professionals must conduct themselves in their relations with KPMG in Brazil, other professionals, clients and the community. It also describes the resources and channels available to provide assistance on the themes it addresses.
The Code was updated in 2012 to reflect recent changes in standards, regulations, laws and codes of professional ethics. It now addresses specific anti-bribery and anticorruption commitments and provides clarity on KPMG's broader responsibilities, such as how we can contribute to development and sustainability.
Global Code of Conduct Commitments G4-56
Our professionals
Professionals, partners, subcontractors, consultants and others with whom we work when providing or supporting professional services.
- Support our professionals in being objective, ethical and professional
- Encourage our staff to address ethical and professional concerns without fear of retaliation
- Invest in developing our professionals so they can achieve their full potential
- Cultivate an inclusive and collaborative culture which is free from intimidation, discrimination and harassment, where all are treated with respect and dignity
- Respect the confidentiality of our professionals' personal data
- Provide a safe and healthy working environment
- Provide flexibility between professional/private life
- Implement a fair approach for compensation
Our network
The organisational structure that connects KPMG International's member firms around the world
- Accept appropriate clients and only accept an engagement if we can complete it to our high standards of quality
- Work with clients, suppliers and subcontractors that meet KPMG's main ethical standards
- Improve quality by developing and applying KPMG methods and procedures
- Handle challenging situations correctly by using the professional ethics and consulting experience of KPMG personnel to draw the right conclusions
- Always strive to protect and enhance the KPMG brand and reputation
- Keep assets and resources secure and only use them for appropriate commercial purposes
Our communities
Markets, locations, authorities and companies in which or with which we operate and to which we are committed
- Enhance the role of the accountancy profession and instil confidence in the global capital market
- Help improve the operation of the market economy
- Act as a responsible corporate citizen - playing an active role in global initiatives related to climate change, sustainability and international development
- Manage our environmental impacts
- Follow high standards of ethical conduct globally, and uphold the ten principles of the United Nations Global Compact
- Work with other companies, governments and charities to build stronger communities
Clients of member firms
Organisations and individuals to whom we - or any member firms of KPMG International - provide professional services
- Deliver high-quality services to clients, in line with our qualifications, experience, professional commitments and contractual terms
- Act legally, ethically and in the public interest
- Maintain independence and objectivity, avoiding real or apparent conflicts of interest
- Ensure client confidentiality and only use information for appropriate professional purposes
- Promote member-firm services honestly and in complete fairness
- Forbid bribery and acts of corruption by professionals and never tolerate illegal or unethical conduct by clients, suppliers or authorities
Global Marketing Compliance (GMC) and Global Quality and Risk Management Manual (GQ&RM Manual)
These provide guidelines to be followed by the communication and marketing teams of member firms to ensure global brand consistency, maintain ethical and effective communication with our stakeholders, control reputation risks and manage client expectations on services provided, by communicating clear and objective information. Below are a few of the salient features of these two documents:
- Marketing - All communication and marketing material prepared by KPMG is revised by qualified professionals accredited in GMC. In 2014 there were no instances of noncompliance or warnings related to our regulations or codes. G4-PR6 | PR7
- Contracts - Based on the GQ&RM, our contracts provide full transparency to clients about details of the engagement, including its scope, deliverables, schedule, fees, client responsibility, subcontracting and responsibilities of KPMG in Brazil. G4-PR3
- People, Performance and Culture - KPMG in Brazil has a specific policy statement in place establishing rules on relations with stakeholders in order to avoid conflicts of interest and ensure the Organisation operates in an ethical and independent manner.
- Traceability and Independence - This system allows us to monitor compliance with our investment policies in the dealings of KPMG and our partners and managers. The system contains a list of public stock corporations, their branches and financial institutions and the types of securities they issue. It also includes a list of investments held by KPMG in Brazil and other financial relationships. System data is continuously updated by our Independence function and must be reviewed prior to acceptance of a new client. Before acquiring securities, all leaders must use the System to determine whether the investment is restricted. They are also required to communicate all movements in individual investments within 14 days of purchasing or selling investments. If a security subsequently becomes restricted, security holders receive an automatic notice stating that they must dispose of the restricted investment. G4-41