Anti-corruption commitment

Deloitte Global’s anti-corruption policy includes requirements for Deloitte firms' own anti-corruption programmes 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 firm anti-corruption leaders work closely with senior Deloitte leaders to build and enhance a globally consistent, internal anti-corruption program across the Deloitte organisation, which includes 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;
• Annual Deloitte firm anti-corruption self-assessments, guidance and tools (including guidance on anti-corruption testing and monitoring) to measure the effectiveness of anti-corruption programs across Deloitte;
• A globally consistent process to perform anti-corruption due diligence on nonclient 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;

• Supporting activities—including communications, workshops and webinars—to facilitate the sharing of leading practices; and

• An annual confirmation from each member firm to Deloitte Global that all of 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.

Additionally, Deloitte Global has a written policy requiring member firms to escalate corruption¹ incidents meeting established criteria to the appropriate Deloitte Global senior leaders. In FY2022, no substantiated incidents of corruption were reported to Deloitte Global under this policy.

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 review programme to assess compliance with anti-corruption policies and drive continuous improvement in Deloitte firm anti-corruption programmes.

¹ For the purpose of this disclosure, “corruption” is defined as any form of bribery including offering, promising, giving, accepting or soliciting anything of value for the purpose of gaining or securing any improper business advantage.