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Acknowledgement that this is one of the trickier subjects

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* As someone who works for KPMG, there are restrictions on what you and your immediate family members can invest in

* This applies to client-facing (but it is worth everybody understanding)

* What you can and can't invest in is related grade and capability area

* Not just about investments - this about your role outside of KPMG and what your family members do

Restrictions on direct financial interest:

* Direct financial interest: It's not permissible to hold a direct financial interest (stocks/shares/bonds) in any KPMG audited entity

Additionally...
* Partner Equivalent restrictions
* Audit restrictions

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* Different restrictions apply to different types of audited entity
* You can only offer these entities certain services based on their classification
* You can only offer permitted services to PIEs/OEPIs

Links to service permissibility information (and learners should know where to look for this information)

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2. How do I know what restrictions apply?  

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2. How do I know what restrictions apply?  

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That depends on the entity you are dealing with - you can use Sentinel to identify audited entities and affiliates (there are separate 'how to' guides available)

Introduction to Sentinel (what it is, what it does, why they need to use it)

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Submitting a sentinel request

Can threats to independence be safeguarded? Threats and safeguards analysis

Remember the third party test "would a reasonable and informed third party think it was reasonable to have this relationship"

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* of mind
* of appearance

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3. How do I know what investments are allowed? 

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3. How do I know what investments are allowed? 

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* You must check KICS before you invest - Partners and Partner Equivalents must pre-clear (mandatory)
* KICS is a tool that records all investments - KPMG Independence Compliance System (KICS)
* Know how to use the KICS tool (links to 'how to' guides)
* For partners and PEs the partner independence team maintain this for you

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* Use KICS - it's a tool that records all investments - KPMG Independence Compliance System (KICS)

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5. External activities and additional employment

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5. External activities and additional employment

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* There are rules around what you do outside of KPMG (i.e you can't be a director etc) strict rules around additional employment
* Understand what external activities and additional employment you can and can't engage with
AND how you can notify KMPG and gain approval
* Complete a form on the intranet

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6. Family relationships with audited entities

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6. Family relationships with audited entities

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You need to report any close relationships with audited entities by completing a form on the portal

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7. Leaving KPMG to join an audited entity

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7. Leaving KPMG to join an audited entity

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Brief point - you might need to know this in the future

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Links to guidance on how to assess service permissibility
Who to contact for support

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What is an audited entity?
Affiliates
UK PIES/OEPI
SEC

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Links to guidance

Who to contact for support: different teams for different restrictions

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Links to guidance

Who to contact for support

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What are the consequences: what happens if it goes wrong

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What are the consequences: what happens if it goes wrong

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Failure to comply - the firm and you personally are exposed

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Everyone

Client facing / non-client facing
Audit and not audit

But there are different rules

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* Covered persons
* Immediate family