Governance

Our Purpose and Values guide everything we do

KPMG is here to help bring positive change, which can only be achieved with strong governance. Governance creates the framework that drives purposeful activity. It helps us align our financial and societal performance, ensuring we are considering our economic, environmental, and social impact in all that we do, both internally and in our work with clients.

Driven by our Values that guide our actions and our Purpose to inspire confidence and empower change, we are committed to the highest standards of personal and professional behavior. As the pressures on business and society evolve and intensify, we believe our Purpose remains as relevant as ever.

We’re committed to making sustainability the watermark that runs through our business. Growing awareness of sustainability issues has led to strengthened governance, which frames our activities and supports robust risk management, including ESG risks, when working with clients.

We apply a sustainability lens across our audit, tax, legal, and accountancy, and advisory services, globally, regionally, and locally, and work to equip our people with the necessary knowledge and skills.

Ongoing efforts involve enhancing cross-functional collaboration, continually reinforcing governance structures, and providing necessary training to help ensure a clear, responsible, and resilient approach to sustainability.

Our commitments

1. Purposeful business

Always act with a clear purpose.

2. Acting transparently with accountability and integrity

Act lawfully, ethically, and in the public interest.
Work against corruption in all its forms, including extortion and bribery.

3. Respecting human rights

Respect human rights

01. Purposeful business

Our commitment:

Always act with a clear purpose.

At KPMG, we recognize that trust is foundational to our business. We can only earn that trust by acting with purpose and delivering our high-quality work in a way that contributes to society today and in the future. Our strong governance and structure support consistency of service quality and adherence to our Values, used across the organization to guide our day-to-day behaviors. As stewards of the business, we continually consider emerging risks and seek to maintain the trust of our clients through responsible business practices and policies.

KPMG firms are focused on delivering high-quality work that makes a meaningful impact now and for the future; building inclusivity and profitability that provides rewarding careers today and for generations to come. Our ambition is to drive growth across our business and to become the most trusted and trustworthy professional services organization, delivering sustainable growth to all our stakeholders. It’s an ongoing process, to which we are fully committed .

Our Values and what we stand for

Our Values guide our day-to-day behaviors, informing how we act, the decisions we make, and how we work with each other, across the 140+ countries and territories that the KPMG firms operate in. They’re embedded across the entire employee journey, in our business processes, and in our stakeholder interactions.

By living our Values and considering the impact of our work from a broad range of perspectives, we aim to be a purposeful business, fostering prosperity and helping to address some of the key issues facing our people, clients, stakeholders, and wider society.

Our Purpose

Inspire confidence. Empower change.

By inspiring confidence in our people, clients, and society, we help empower the change needed to solve the toughest challenges and lead the way forward.

KPMG’s Global Values Week:
Building a values-led firm of the future. At the start of FY24, the KPMG global network came together to celebrate Our Values during a week-long series of events. Global Values Week engaged our people in dialogue around our five Values and their role in our daily work. We also launched Values Immersion and a Board Game for new joiners to engage with our values. Leadership-led sessions will continue in FY25.

People

We are a people business.

Our people want opportunities to do meaningful and impactful work while developing a thriving career in an inclusive, diverse, rewarding, and caring culture.

Clients

We build trust and confidence in business and the capital markets

Our clients seek our expertise to overcome the challenges ahead and to grow sustainably. We help safeguard the integrity of financial reporting and the capital markets.

Society

We have a responsibility to build a sustainable future.

Society demands a fairer, more equitable, future that doesn’t come at such a significant cost to its people and our planet.

Our structure and governance

KPMG has strong governance for overseeing our activities, setting policies, and aligning our strategy with our Purpose. KPMG International Limited1 acts as the coordinating entity for the overall benefit of the KPMG global organization. It does not provide professional services, directly or indirectly, to clients. Its governance bodies comprise the Global Council, the Global Board (including its committees), the Global Management Team (GMT), and Global Steering Groups.

Global Council:
The Global Council focuses on high-level governance tasks and provides a forum for open discussion and communication among member firms. Among other things, the Global Council elects the Global Chairman and approves the appointment of Global Board members. It includes representation from 56 KPMG member firms.

Our structure and governance

Global Board:
The Global Board is the principal governance and oversight body, currently consisting of 22 members from diverse countries that reflect KPMG’s global presence and geographic footprint.

The Global Board annually reviews KPMG’s global climate strategy, as well as broader sustainability reporting as part of the annual “Our Impact Plan” progress updates.

Find out more about our global governance in our KPMG International Transparency Report 2024.

For detailed descriptions of individuals and committees with management responsibility over climate-related risks and opportunities, read our Climate Risk Report.

_{1. KPMG International Limited provides services and support to, or for the benefit of, KPMG firms and does not provide professional services directly, or indirectly, to clients. Professional services to clients are exclusively provided by KPMG firms who remain solely responsible for and liable in respect of these services.}

Global Management Team (GMT):
The Global Board has delegated certain responsibilities to the Global Management Team. These include working together with the Executive Committee to develop and jointly recommend the global strategy to the Global Board for its approval. They also have oversight of the activities of the Global Steering Groups, support KPMG firms with the execution of the global strategy at a local level and hold them accountable against their commitments.

Regional Boards:
Each firm is part of one of three regions, namely the Americas, ASPAC, and EMA. Each region has a Regional Board comprising a regional chairman, regional chief operating officer, representation from any sub-regions, and other members as appropriate. Each Regional Board focuses specifically on the needs of member firms within their region and assists in the implementation of KPMG International’s policies and processes within the region.

KPMG representation in a country may consist of more than one separate legal entity. If this is the case, each separate legal entity will be responsible only for its own obligations and liabilities, unless it has expressly agreed otherwise.

Further details about KPMG International including the governance arrangements, can be found in the “Governance and Leadership” section of the KPMG International Transparency Report 2024.

Client confidentiality, information security, and data privacy

The importance of maintaining client confidentiality is emphasized through a variety of mechanisms, including our Global Code of Conduct. KPMG has policies on information security, confidentiality, personal information, and data privacy. Annual training on confidentiality, information protection, and data privacy requirements is also provided to all KPMG people.

We have a legal framework that provides for adequate safeguards in relation to the processing of personal data in a manner that is consistent with laws and regulations and for the protection of privacy and the fundamental rights and freedoms of individuals. This includes safeguards for the international transfer of personal data by data exporters to data importers (including the applicable standards set out in the General Data Protection Regulation (GDPR)) and the protection of client information when transferred between KPMG firms.

“KPMG has strong governance for overseeing our activities, setting policies, and aligning our strategy with our Purpose.”

Where we work with third parties, appropriate controls are included in the terms and conditions of the contracts, including those to protect the confidentiality of information and help ensure the processing of personal data occurs in a manner that is consistent with applicable laws and regulations.

Cybersecurity and creating a trusted, digital world

Maintaining the trust of KPMG firms’ clients requires us to continually look over the cyber risk horizon and adapt our approach where needed. We’re evolving our global security standards and proactively maintaining compliance to meet the ongoing needs of our business, while actively educating our people in cybersecurity safety protocols and their understanding of collectively managing cyber risks. We also continue to identify and implement enhanced cybersecurity controls to provide an additional level of protection to our data, our KPMG firms’ clients’ data, and other key assets.

KPMG International’s cybersecurity professionals have a variety of backgrounds and experience, including digital transformation, IT, regulatory, and forensics. Together, they continue to drive increased efficiency across the global organization, including the delivery of key investments in managed detection and response: cloud security, security operations, risk quantification, digital identity and zero trust, third-party security, AI, machine learning

KPMG Trusted AI

Artificial Intelligence (AI) is transforming nearly every field of human endeavor and becoming increasingly embedded in all aspects of everyday life for both businesses and individuals alike. As KPMG works to fully harness the power of AI and accelerate adoption, we recognize that advanced technologies can introduce complexity and risks that need to be addressed clearly and responsibly. We are excited about the opportunities that AI presents but remain equally committed to upholding the ethical standards for AI solutions that align with our Values and professional standards, and that foster the trust of KPMG clients, people, communities, and regulators.

KPMG Trusted AI is our strategic approach and framework to designing, building, deploying, and using AI solutions in a responsible and ethical way to ensure we can accelerate value with confidence. Please check KPMG Trusted AI and our 24 hours of AI training event available to all KPMG colleagues across the organization, for more information. The field of AI is rapidly evolving. As the technology advances and legal, ethical, risk and regulatory standards mature, we

and advanced analytics, Internet of Things, and operational technology security. As cyber threats grow in volume and sophistication, KPMG teams are bringing technological expertise, deep business knowledge and innovation, to work with clients in creating a more resilient and trusted digital world.

will continue to review and evolve our approach as necessary.

Our approach to identifying risk

At KPMG, we recognize how important it is to identify, manage, and plan for risks. Every KPMG firm is required to identify and manage its risks through a formal Enterprise Risk Management (ERM) process for which each firm’s leadership is responsible.

KPMG firms report the results of their ERM processes annually to KPMG International’s ERM team, which aggregates and analyzes the information and shares insights and risk exposures across the KPMG global organization. The global organization’s client and engagement acceptance and continuance policies and processes are designed to help KPMG firms identify and evaluate potential risks, including relevant ESG risks, prior to accepting or continuing a client relationship or performing a specific engagement.

KPMG firms evaluate whether to accept or continue a client relationship or perform a specific engagement. Where client or engagement acceptance (or continuance) decisions pose significant risks, additional approvals are required.

Supporting those charged with governance

Board members play a crucial role in driving strong governance, but the demands of their position come with significant challenges. KPMG in Belgium’s Board Leadership Center (BLC) is dedicated to supporting board members in strengthening their commitment and capabilities, helping them foster long-term sustainability and build stakeholder confidence.

As part of a global network spanning more than 40 countries and territories, the BLC in Belgium connects with directors and business leaders to address key governance challenges and promote continuous improvement in both public and private companies. Leveraging insights from KPMG professionals and subject matter experts in Belgium and beyond, the BLC provides practical thought leadership on critical topics such as risk and strategy, talent and technology, globalization and compliance, financial reporting, and audit quality—all through a board-focused lens.

Examples of the insights and support the BLC offers can be found here.

02. Acting transparently with accountability and integrity

Our commitment:

Act lawfully, ethically, and in the public’s interest.
Work against corruption in all its forms, including extortion and bribery.

The KPMG Global Code of Conduct is regularly reviewed to make sure it clearly reflects our Values and the commitments and responsibilities that KPMG people have to each other, our clients, and the public. In line with the Global Code of Conduct, we strongly support a speaking-up culture and set out a clear process for advice on, or the reporting of, illegal or unethical behavior. The new KPMG CARE framework (Consider, Assess, Respond, Evolve) helps our people practice and build confidence in making ethical decisions.

We’re committed to the highest standards of personal and professional behavior in everything we do.

Within our Global Code of Conduct (our Code), we outline the commitments and responsibilities we have to both our internal and external stakeholders.

It shows how our Values and Purpose inspire our greatest aspirations and guide all our behaviors and actions. It defines what it means to work at, and be part of, the KPMG global organization, as well as our individual and collective responsibilities. We regularly review our Code to make sure it’s a clear reflection of these principles and expectations. In addition, everyone at KPMG can expect to be held accountable for their behavior, consistent with our Code, and are required to confirm their compliance with it on a yearly basis.

KPMG firms and professional accountants are also bound by the International Code of Ethics for Professional Accountants, including International Independence Standards issued by the International Ethics Standards Board for Accountants (IESBA). KPMG’s ethical principles and expectations are in alignment with these standards.

KPMG firms provide regular training to partners, directors, and employees on a range of topics, including our Code and our anti-corruption policies and procedures. The training emphasizes the importance of making ethical decisions even when under pressure, and speaking up to ask questions, respectfully challenge, and raise concerns when we are uncertain or when something does not seem right.

Driving ethical decision-making

At KPMG, we know that trust is earned by doing the right thing. As the world rapidly changes and becomes more complex, this simple principle has never been more important. KPMG’s ethical decision-making framework CARE, which was created in 2023 and is used by KPMG firms, steers us to ethical decision making and supports our Purpose, Values, and Code of Conduct, centered on building and reinforcing trust.

The CARE framework helps our people make ethical decisions, especially when faced with a challenging situation or ethical dilemma. It also reminds them that they do not have to make these decisions alone.

The CARE framework is backed by a portfolio of supporting materials and guides, including facilitated discussions to enable our people to practice and build confidence in making ethical decisions.

Care: Ethical decisionmaking frameword

Consider

what is the issue

Assess

options to address the situation

Respond

with decision

Evolve

and reflect

Consistent with being signatories to the UN Global Compact and the World Economic Forum’s Partnering Against Corruption Initiative (PACI), we work against corruption in all its forms, including extortion and bribery. Our Code clearly states that we don’t tolerate illegal or unethical behavior within KPMG or from clients, suppliers, or public officials with whom we work. Bribery and corruption are unethical, even in situations where they may not be considered illegal in a particular jurisdiction.

All KPMG firms have processes in place to assess prospective clients, third parties, and suppliers in relation to bribery and corruption. KPMG firms must also assess their bribery and corruption environment annually and establish and maintain processes to monitor, manage, and control how their personnel and their agents interact with government entities and government officials to ensure compliance with applicable laws and regulations and to maintain public trust. Find out more about our position on bribery and corruption.

Our commitment to continuously strengthen our ethical culture

Across the KPMG organization, we take any incidents that are inconsistent with our Values or contrary to our Code very seriously. When KPMG firms fail to meet these high standards we set for ourselves, or those set by the organizations that regulate us, we address those challenges by taking steps to strengthen our ethical culture. This includes leveraging technology to assess our policies and controls.

As a global organization, we remain committed to KPMG firms taking all appropriate actions to address incidents that are inconsistent with our Values.

We understand that trust is built on professional excellence, integrity, and societal impact. The trust of clients and the public is crucial for future growth and success.

Speaking up safely

KPMG has a detailed approach for monitoring and reporting any illegal or unethical acts. Our Code of Conduct, policies, and procedures set out a clear process for anyone seeking advice or wanting to report illegal or unethical behavior, and we openly encourage a culture of speaking up without any fear of reprisal. We prohibit retaliatory behavior when our people report ethical issues, breaches, or suspected breaches in good faith.

To safeguard the principle of holding each other accountable, each KPMG firm commits to having clearly defined channels that allow KPMG people and third parties to make inquiries, raise concerns in relation to providing feedback, and notify reportable matters without fear of reprisal, in accordance with applicable laws and regulations.

Supporting our global and local speak-up culture, KPMG International and KPMG in Belgium have an independent hotline that can be used by KPMG people, clients, and third parties to confidentially report any concerns they may have relating to any activity by KPMG International, KPMG firms, or KPMG people.

03. Respecting Human Rights

Our commitment:
Respect human rights.

The KPMG network is committed to the protection of Human Rights and helping to eliminate all forms of forced, compulsory, and child labor in line with the United Nation’s Guiding Principles on Business and Human Rights. We recognize that we have an important role to play in managing potential harm to people and, as part of our Global Quality & Risk Management processes, have established a risk-based approach to human rights. A key priority is a focus on suppliers, and we continue to refine our approach to addressing modern slavery risks throughout KPMG International’s supply chain.

We are committed to respecting human rights as outlined in our Business and Human Rights Statement, which is in line with the United Nation’s Guiding Principles on Business and Human Rights and builds on our longstanding support for the UN Global Compact. This means supporting the protection of human rights, avoiding being complicit in human rights abuses (including

those involving business relationships) and helping to eliminate all forms of forced, compulsory, and child labor. Additionally, our Global Code of Conduct sets out our commitments to:

Work with clients, suppliers, and subcontractors that live up to KPMG’s core ethical standards;
Act lawfully, ethically, and in the public’s interest;
Not tolerate behavior within KPMG, by clients, suppliers, or public officials with whom we engage, that is illegal, unethical, or violates human rights; and
Champion an inclusive and collaborative culture that is free from bullying, discrimination, and harassment, where everyone is treated with respect and dignity.

The policies and procedures that KPMG firms across the globe have agreed to implement are consistent with the UN Declaration of Human Rights, the UN Guiding Principles, the International Labor Organization Core Conventions, and the OECD’s Guidelines for International Enterprises.

KPMG International and KPMG firms:

Undertake to avoid causing or contributing to adverse human rights impacts through their own activities, and address such impacts when they occur; and
Seek to prevent or mitigate adverse human rights impacts that are directly related to their operations, products, or services through their business relationships. KPMG member firms recognize our important role in managing potential harm to people through a risk-based approach to human rights due diligence.

The KPMG network monitors human rights impacts across our global organization as part of our Global Quality & Risk Management processes.

The KPMG International Hotline can be used to raise any concern relating to a human rights issue. We take reports received by the International Hotline seriously, and we respond and agree on appropriate actions to be taken by KPMG firms.

“We are committed to respecting human rights as outlined in our Business and Human Rights Statement, which aligns with the United Nations’ Guiding Principles on Business and Human Rights and builds on our longstanding support for the UN Global Compact.“

Modern slavery in the supply chain

While the professional services industry is not typically considered a high-risk sector for labor-related issues such as slavery and human trafficking, we recognize our supply chain poses a higher risk in certain industries and locations. A key priority is to focus on our suppliers, particularly on reviewing, assessing, and monitoring high- and medium-risk suppliers.

The KPMG global organization has continued to refine and improve our approach to addressing modern slavery risks throughout KPMG’s supply chain by leveraging existing best practices across our KPMG firms. Our annual selfassessment supplier outreach now incorporates specific high-risk factors such as a high-risk service type and/or location, and certain high-risk business models (such as a reliance on vulnerable or temporary work staff). Risk analysis is complemented with public scrutiny research, using trusted external sources.

Where a potential risk factor is identified, we complete an additional supplier assessment to evaluate whether relevant policies, standards, and controls are in place to prevent and address modern slavery risks in the supplier’s organization as well as across their own supply chain.

Our Code of Conduct for suppliers and vendors

In line with the KPMG International Supplier Code of Conduct, we have a KPMG in Belgium Vendor Code of Conduct that more clearly articulates the expectations we have of our suppliers and vendors, particularly with respect to:

Ethical conduct and integrity: We expect our suppliers and vendors to uphold the highest levels of ethics and integrity in line with KPMG’s professional standards.
Modern slavery and respecting human rights: We expect our suppliers and vendors to respect human rights, promote fair labor practices, and uphold the same standards and practices as we do in eradicating modern slavery and human trafficking.
Inclusion and diversity: We expect our suppliers and vendors to foster an inclusive environment that is free from discrimination and promotes equal opportunity. Our suppliers and vendors are encouraged to establish appropriate inclusion, diversity, and equity (IDE) goals for their organization.
Environment: We expect our suppliers and vendors to collaborate with us to support our climate goals and can provide evidence of programs or initiatives within their own organizations that help reduce their environmental impact.

The KPMG in Belgium Vendor Code of Conduct is an important step in formalizing our requirements for suppliers and vendors and incorporates language in our contracts that underpins our ESG commitments.

Similar to KPMG International’s Supplier Code of Conduct’s reference to the KPMG International Hotline being accessible to third parties to confidentially report any concerns they may have relating to the fulfillment of a KPMG contract, the KPMG in Belgium Vendor Code of Conduct also specifically references KPMG in Belgium’s Whistleblowing hotline.

Incorporated into our standard supplier policies for contracting, KPMG International and KPMG in Belgium regularly review their supplier and vendor Code of Conduct to ensure continued alignment with our ESG commitments.