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KPMG's Code of Conduct

Our Promise of Professionalism

At KPMG, our promise of professionalism to each other, our clients, and the capital markets we serve, compels us to align our culture of integrity with our values, words, and actions.

By setting high standards for ourselves, and our clients, our commitment to upholding KPMG’s values is clear: There is never a situation when compromising our standards is either expected or acceptable. To support our culture of integrity, KPMG has developed a robust ethics program that includes our Code of Conduct.

KPMG's Code of Conduct – Promise of Professionalism

Our Code of Conduct defines the values and standards by which KPMG conducts business. It is designed to provide partners and employees in the U.S. firm with a clear understanding of the standards of conduct that pertain to our respective roles in the firm; the Code of Conduct is intended to be a road map to help guide our actions and behaviors at KPMG. Our Code outlines the resources available to help each of us fulfill our personal responsibility to both understand and comply with the firm’s standards.

Every year, all members of our firm are required to affirm their agreement to comply with the Code of Conduct. Additionally, all partners and employees complete mandatory training that reinforces the principles of the Code and further builds understanding of the firm’s expectations. Through the Code of Conduct and the vigilance of all of our partners and employees, we continue to work hard to maintain a culture within KPMG that values integrity in all areas of our organization.

Our promise of professionalism

KPMG's Code of Conduct

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Questions and Answers about the KPMG US Code of Conduct

What is the KPMG US Code of Conduct?

The Code of Conduct establishes the ethical, professional, and legal standards expected of all KPMG personnel and connects the firm's purpose and values to everyday decision-making and behavior.

Why does KPMG have a Code of Conduct?

The Code helps KPMG professionals comply with laws, regulations, professional standards, and firm policies while maintaining trust, quality, accountability, and a commitment to the public interest.

Who is required to comply with the Code?

All KPMG partners and employees are required to comply with the Code, complete required training, and annually confirm their adherence through the Annual Compliance Confirmation process.

How does the US Code relate to KPMG's Global Code of Conduct?

The U.S. Code aligns with KPMG's Global Code of Conduct while incorporating local legal, regulatory, professional, and firm requirements applicable in the United States.

What are KPMG's core values?

KPMG's values are Integrity, Excellence, Courage, Together, and For Better. They guide decision-making, workplace behavior, client service, and leadership.

What responsibilities do all KPMG professionals have under the Code?

Personnel are expected to take ownership, lead by example, stay informed, consult when necessary, stand firm under pressure, and speak up about potential violations that may affect KPMG or its clients.

What additional responsibilities do KPMG leaders have?

Leaders are expected to model ethical behavior, support and develop their teams, enforce standards consistently, exercise sound judgment, accept accountability, and prevent retaliation.

What should KPMG professionals do if something does not seem right?

Employees are expected to speak up, seek guidance, and report potential violations of law, policy, ethical standards, or professional requirements through an appropriate Channel of Communication.

Can KPMG professionals report concerns anonymously?

Yes. The KPMG Ethics and Compliance Hotline allows anonymous or confidential reporting and is available 24 hours a day, seven days a week through an external third-party provider.

How does KPMG protect people who report concerns?

KPMG prohibits retaliation against anyone who raises a concern or participates in an investigation in good faith, even if the concern is not substantiated. Retaliation may result in discipline, including separation from the firm.

What reporting and consultation resources are available to KPMG employees?

Resources include People Management Leaders, engagement and practice leaders, Risk Management, Talent and Culture, Ethics and Compliance, the Office of General Counsel, firm leadership, and the Ethics and Compliance Hotline.

Why is professional development emphasized in the Code?

KPMG expects personnel to complete required training, maintain applicable licenses and certifications, stay current on relevant requirements, and continuously build technical, business, and leadership capabilities.

How does KPMG support an inclusive and respectful workplace?

KPMG is committed to an inclusive workplace free from discrimination and harassment where individuals are treated with respect and dignity and employment decisions are based on qualifications, experience, abilities, performance, and business needs.

What is KPMG's position on human trafficking and forced labor?

KPMG prohibits human trafficking, forced labor, and unlawful child labor and expects clients, suppliers, subcontractors, consultants, and other third parties to follow the same ethical principles.

What are KPMG employee responsibilities for workplace safety and well-being?

Personnel should follow safety and security requirements, prevent unauthorized workplace access, use alcohol responsibly at work-related events, avoid working while impaired, follow travel guidance, and report urgent threats or safety concerns.

How does KPMG define quality client service?

Quality means performing work competently and objectively, with due care and professional skepticism, using approved methodologies, appropriate skills and resources, effective supervision, open communication, and consultation when needed.

 

Why is independence critical at KPMG?

Independence supports objectivity and public trust. Personnel must identify and address personal, financial, employment, business, and service relationships that could impair, or appear to impair, independence.

When can work begin on a new client or engagement?

Work may begin only after required client and engagement acceptance procedures are completed, including relevant conflict and risk reviews, a Sentinel Approval Number, required CEAC approvals, resolved comments, and an executed contract.

How does KPMG protect confidential information?

Confidential information should be collected only when needed, shared on a need-to-know basis, limited to the minimum necessary, protected from unauthorized disclosure, and securely disposed of when retention is not required.

Can KPMG partners and employees trade on information learned through client work?

No. Employees may only use client information for proper business purposes and never for personal gain. Trading on material non-public information, or sharing it with others, is prohibited and may violate the law. Additional firm restrictions apply to securities of clients served and Restricted Entities.

What responsibilities apply when working with government clients?

Personnel must comply with applicable government-contracting laws, rules, security requirements, proposal and communication restrictions, contractual terms, accurate billing requirements, and required consultation or pre-clearance processes.

What should employees do if they suspect a client may be violating the law?

Employees should promptly raise known or suspected non-compliance with the engagement partner or another appropriate channel so KPMG can evaluate the issue under professional standards and firm reporting protocols.

Can employees serve on nonprofit boards or volunteer during work hours?

Nonprofit service may be permitted, but personnel must review independence requirements and report applicable board roles. Eligible employees may use approved Impact Volunteer Hours for qualifying activities, subject to PML approval and firm requirements.

What rules govern political activities and political contributions?

Political activities, contributions, lobbying, candidacy, appointments, and interactions with public officials may require consultation, pre-clearance, reporting, or approval because KPMG is a government contractor and is subject to pay-to-play and other restrictions. Employees may not make any political contribution on behalf of the firm without obtaining approval. The firm is prohibited by federal law from making any federal political contributions.

What does KPMG mean by ethical marketing and fair competition?

KPMG personnel must market services honestly, describe qualifications accurately, use factual comparisons, avoid misleading promises, protect competitively sensitive information, and avoid agreements that could restrict competition or hiring.

What is KPMG's policy on bribery, corruption, gifts, and entertainment?

Personnel may not offer, solicit, or accept anything of value intended to improperly influence a decision or professional judgment. Cash, cash equivalents, facilitation payments, and arrangements that could appear improper are prohibited or restricted.

What are KPMG's gift and entertainment thresholds?

The Code states a general firm limit of $100 for gifts and $250 for entertainment when the provider is present. Amounts above those limits require advance approval, and anything provided to government officials or employees is subject to stricter pre-approval rules.

How should employees protect technology and information assets?

Employees must use approved technology, safeguard credentials and devices, avoid unauthorized software and storage services, protect confidential information, recognize phishing and similar threats, and promptly report information or cybersecurity incidents.

Can employees use public AI tools with KPMG or client information?

Employees must not use unapproved generative AI or public AI resources in ways that disclose confidential information. AI use must align with client agreements, approved technology requirements, firm policy, and KPMG's Trusted AI principles.

What are KPMG's economic sanctions and export-control responsibilities?

Personnel must follow firm processes for clients, engagements, third parties, technology, and controlled information; identify potential sanctions or export-control issues; and consult the Financial Crimes & Trade Compliance Program Officer when required.

How does KPMG protect intellectual property?

Personnel must protect KPMG intellectual property, respect client and third-party rights, use materials only with authorization, avoid bringing proprietary information from former employers, and not retain firm or client confidential information when leaving KPMG.

Why are accurate time, expense, and business records important?

Employees must report all time worked to the proper code, submit only legitimate and reasonable business expenses, and maintain accurate engagement documents, deliverables, performance records, invoices, and other business information.

What should employees know about conflicts, outside employment, legal matters, media, and social media?

Personnel must disclose and manage relevant personal relationships and conflicts, follow outside-employment rules, preserve documents and consult the Office of General Counsel on legal matters, direct media inquiries to Corporate Affairs, and protect confidentiality and the KPMG brand in public and social-media communications.

Ethics and Compliance

KPMG—through its people, values, programs, and policies—has made it a priority to help ensure that we have an ethical culture where everyone embraces a sense of personal responsibility for doing the right thing in the right way.

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