Anti-corruption commitment

Deloitte Global’s anti-corruption policy includes requirements for Deloitte firms’ own anti-corruption programs and addresses matters such as bribery, facilitation payments, political and charitable contributions, and gifts and entertainment. This policy requires Deloitte firms to conduct business in accordance with certain anti-corruption principles, including that Deloitte neither makes nor accepts bribes, and does not induce or permit any other party to make or receive bribes on our behalf.

The Deloitte Global anti-corruption team and Deloitte firms’ anti-corruption leaders work closely with senior Deloitte leaders to support and enhance local anti-corruption programs across the Deloitte organization, which include, amongst others, the following elements:

• Appointment of an anti-corruption leader who is responsible, with oversight from the applicable Deloitte firm’s leadership or governing body, for the applicable Deloitte firm’s anti-corruption program;
• Anti-corruption testing and monitoring to help measure the effectiveness of local anti-corruption programs;
• A process to perform anti-corruption due diligence on non-client third parties, including subcontractors, marketplace alliances, vendors, and suppliers;
• A process for Deloitte firms to perform or update corruption risk assessments at least annually;
• Channels for Deloitte people to report concerns;
• An annual confirmation from each Deloitte firm to Deloitte Global that its people have read, understood, and agree to comply with the local anti-corruption policy and are not in violation of this policy, and understand their obligation for reporting actions that do not comply with this policy.

Deloitte Global has a written policy requiring Deloitte firms to escalate corruption incidents meeting established criteria to the appropriate Deloitte Global senior leaders.

All Deloitte people are required to complete anti-corruption training—after being hired and every other year thereafter—that includes applicable policies, corruption red flags, and case scenarios.

Deloitte Global conducts a program review to assess compliance with anti-corruption policies and drive continuous improvement in Deloitte firm anti-corruption programs.