Ethics at Deloitte

Leading Ethics at Deloitte

Respected organizations around the world trust Deloitte member firm practitioners to execute their most ambitious projects, manage highly confidential information, and develop ideas and approaches that can alter the course of their businesses. That trust has been – and continues to be – earned thousands of times each day by Deloitte member firm practitioners.

Ethical behavior among Deloitte people is fundamental and not negotiable. That’s why the Deloitte Global Chief Ethics Officer and the Deloitte Global Ethics team work with member firm leaders and Ethics Officers to continually enhance the culture of integrity across the organization through implementation of ethics programs. Together, they help keep a continuous spotlight on ethics by communicating expectations of behavior and working to embed ethical decision-making into existing processes and new initiatives.

Deloitte’s commitment to ethics

At Deloitte, we have placed ethical culture and values at the heart of our agenda, and we understand the critical responsibility Deloitte has to continue to build trust and serve the public interest. Driving a proactive approach to ethics, and building and sustaining a culture of integrity, helps Deloitte practitioners make the most appropriate professional decisions.

The Deloitte network of member firms conducts business in accordance with applicable laws, regulations, and professional standards, providing quality service to clients and building trust and confidence in global markets. In addition, Deloitte member firms implement internal policies and standards to address important professional behavior that may not be governed by professional requirements.

The Global Principles of Business Conduct (“Global Code”) for the Deloitte network outline the commitments that each of us make. Based on our Shared Values, the Global Code reflects our core belief that, at Deloitte, ethics and integrity are fundamental and not negotiable.

Consultation goes to the heart of the Deloitte culture. Individuals are encouraged to consult with a team leader or other senior leader, or their Deloitte firm Ethics Officer or Talent/HR leader. Additional support is found in relevant policies, Deloitte firm Codes of Conduct, and other guidance. As well as this, formal ethics reporting channels are available for those who seek a confidential route for consultation.

Deloitte’s ethics program

The Deloitte Global Ethics team and Deloitte firms’ Ethics Officers continue to work closely with senior Deloitte leaders to strengthen and enhance the organization’s ethics program. The following codes and policies are foundational to the ethics program and help to set clear expectations:

• The Global Code and Deloitte firms’ codes of conduct, which provide additional local guidance, detailed expectations, consultation channels, links to policies and guidelines, and further support for Deloitte people;
• A global ethics policy that sets out the requirements for Deloitte firms’ ethics programs, along with an Ethics Officer Playbook, to set clear expectations and reinforce the strategic role and responsibilities of Deloitte firms’ Ethics Officers;
• A global anti-discrimination and anti-harassment (including discrimination on the grounds of sex, gender identity, or sexual orientation, and sexual harassment) policy that sets out the requirements for Deloitte firms’ own individual policies, subject to local laws. The global policy requires anti-discrimination and anti-harassment training for all Deloitte people upon joining and every two years thereafter;
• A global familial and intimate personal relationships policy that sets out the requirements for Deloitte firms’ own individual policies and processes, subject to local laws. This policy is designed to help ensure that working relationships are, and are perceived to be, objective, fair, and at arm’s length, and to mitigate real or perceived conflicts of interest; and
• A global non-retaliation policy that sets out the requirements for Deloitte firms’ own individual policies and processes, subject to local laws. This policy articulates Deloitte’s commitment to a non-retaliatory workplace, with monitoring procedures to support this.

Training, consultation channels, support activities, and review programs are also core elements of the ethics program, in helping Deloitte people understand and apply these expectations. These include:

• Ethical due diligence processes for Deloitte firm CEOs, board chairs, and other senior leaders, and enhanced expectations for Deloitte firms’ boards of directors in governing ethical culture, ethical risks, and ethics program agendas;
• Deloitte ethics training programs – including online courses, classroom and virtual programs, and facilitator-led interactive case discussions – and communications campaigns. Ethics training is required for independent contractors and for all Deloitte people, including all new hires upon joining Deloitte; upon promotion to manager, senior manager, and partner (specific to their roles); and for all Deloitte people every two years. Additional ethics training is also delivered to members of the Deloitte Global Board of Directors and Deloitte firm boards on a periodic basis. This training emphasizes how boards can influence organizational ethics and the importance of setting a strong tone from the top;
• Channels for consultation and reporting ethics concerns that emphasize confidentiality and nonretaliation – directly to Ethics or Talent teams; via managers, team leaders, or managing directors, and member firm partners; or using the third-party ethics helpline Deloitte Speak Up and similar, third-party local services – that are supported by training and communications;
• Support activities – including communications, webinars, and continuing education – to facilitate the sharing of leading practices among Deloitte firm Ethics teams;
• An annual ethics survey, guidance on conduct risk assessment, and other tools to measure the effectiveness of ethics programs across Deloitte;
• An annual confirmation by Deloitte people that they have read, understood, and are following the Global Code; and
• Detailed review programs to measure and monitor compliance with the global ethics policy and drive improvement in Deloitte firm ethics programs over time.