To help our professionals maintain their personal independence, we provide our professionals access to integrated systems that
contain continuously updated information about companies that are restricted for independence reasons (restricted entities). In
addition to periodic personal compliance audits, we have developed state-of-the-art systems, processes and technology platforms
to comply with independence-related regulatory and policy requirements, which enable early identification of possible instances of
noncompliance. These include:
Tracking & Trading System
Designed for professionals to track and monitor compliance related to personal and immediate family members’
investments and financial relationships, which includes real-time automated monitoring functions. For more than 10
years, we have required professionals to automatically import their security holdings with this tool.
Daily reconciliations
Reconciliations of professionals’ client service hours reported in our time Reporting system to the personal holdings
of our professionals included in our Tracking & Trading System, which identifies potential independence conflicts on a
real-time basis.
Quarterly independence representations
We obtain quarterly representations on the completeness and accuracy of financial interests reported. Semi-annually,
we require professionals to upload to our systems account statements for financial interests held in accounts that
cannot be reported automatically.
Service centre
Reconciles professionals’ uploaded account statements for financial interests held in accounts that cannot be
automatically imported to their reported financial relationships to validate completeness and accuracy of Reporting.
Check Your Assets tool
Designed for professionals to be proactive and compliant with independence rules. Professionals use the tool to check
for independence conflicts before working on a client engagement.
Artificial intelligence
Technology solution that identifies the potential unreported holdings of our professionals included in accounts that
cannot be automatically imported into our system.
Engagement independence and monitoring
Non-audit services: The partner, principal or managing director for each potential engagement undertakes a process that
determines whether independence must be maintained with respect to the client, even if the client is not an attest client. If
independence from the client is required, the partner, principal or managing director must verify, prior to beginning the engagement,
that the services to be provided are permissible and have been pre-approved.
Marketplace business relationships: New marketplace business relationships require reviews by the lead relationship partner and
the Independence & Conflicts Network Business Relationship team. A third-party risk management database of approved marketplace
business relationships is maintained and continuing relationships undergo an independence update at least annually. In addition, all
vendor business relationships are assessed for compliance with established policies and procedures.
