Being an Immediate Family Member of an individual in Deloitte

Why is it important?

There are several regulatory bodies who lay out the rules and requirements to which Deloitte (as a firm, individuals who work here and their IFMs) must adhere, in order to be compliant.

By complying with the independence requirements Deloitte satisfies the expectations of its regulators whilst also maintaining the trust of our clients and the public and protecting Deloitte’s reputation. Effectively this is Deloitte’s license to do business and getting it wrong can result in fines, loss of  reputation and potentially disciplinary action against individuals working at Deloitte that were involved.

Why does it impact me?

Our regulators view Immediate Family Members (IFMs) of those who work at Deloitte as equivalent to the Deloitte professional in many situations.

This means that although you may not work for Deloitte yourself, the financial and/or employment relationships that you hold can impact Deloitte’s ability to remain independent and comply with the regulatory requirements.

It is our role and intention to support you, your family member who works in Deloitte and any other IFMs to be – and remain – compliant.

Whether your spouse works in Audit or any other business area within Deloitte, if you meet the definition of an IFM some level of independence requirements will apply to you and the Deloitte individual.

What financial interests does Deloitte need to know about?

Deloitte’s independence policies apply to financial interests (including, but not limited to those) listed below.

• Brokerage accounts
• Personal pensions and SIPPs – current and former employer pensions
• Employment pensions
• Stocks and shares
• Mutual funds and unit trusts – including ISAs
• Child Trust Funds and Junior ISAs
• Bank Accounts
• Personal lending, including credit cards
• Mortgages
• Assets under your control or influence – e.g. via a Power of Attorney or executorship

Read full list of what must be recorded in our systems – and what you can voluntarily record. This list is the same for you and your family member  who works in Deloitte.

This means you’ll need to:

1. identify which financial interests (accounts/wrappers and underlying investments) you have currently or are proposing to take out;
2. identify if these need to be recorded on Deloitte’s Global Independence  Monitoring System (GIMS);
3. for any new investments, you’ll need to pre-clear the investment prior to acquisition – to ensure it is permitted and not restricted – and if so, record these on our Global Independence Monitoring System (GIMS) within 10 days of  acquisition; and
4. for any existing investments, you’ll need to record these on our Global Independence Monitoring System (GIMS) in a timely manner. 

My Financial Provider Network (MFPN) was created by Deloitte to help ease the administrative burden for people when pre-clearing their investments and/or updating details of investments on GIMS manually. Please visit the ‘My Financial Provider Network’ tile to find out more. 

If any financial investments or relationships that you (or your family member who works in Deloitte) have subsequently become restricted, Deloitte’s Independence team will  contact you (or your family member at Deloitte) to advise you accordingly.

You should be aware that certain restrictions may require you to divest your financial investment and may result in you having to take a loss on an investment, repaying a load that still has favourable rates, or otherwise incurring a cost.

What employment relationships does Deloitte need to know about?

Another area of independence which impacts many Deloitte professionals is the employment relationships of their IFMs – including spouses or spousal equivalents. These rules apply to you (as the spouse or spousal equivalent of someone who works in Deloitte) and does not apply to your own close relatives.

Does it matter where you work? Potentially yes…

It all depends on the role of the Deloitte professional and the role you (as their spouse or spousal equivalent) have with your own employer. If you are employed by a restricted entity, your spouse or spousal equivalent who works in Deloitte will be required to report this in their annual independence return (they may refer to this as their ‘Annual Confirmation’ or ‘ICC’) – but they should report this as soon as possible and not wait for their annual  independence return to be issued. Once reported, Deloitte’s independence team will then analyse the facts and circumstances to see if there would be a conflict under any of the regulatory rules that apply to that specific  restricted entity.

How to know if you work at a restricted entity?

The quickest way is for your spouse or spousal equivalent to search your employer entity on Deloitte’s DESC system.

Alternatively you can contact the Deloitte Independence team yourself on 020 7007 7777 (selecting option 4) and they can check for you.

If you work at a restricted entity, what information will you need to disclose?

Different aspects of your  employment and circumstances can impact independence, so Deloitte will need to consider a range of factors – including those below – to advise on the independence requirements.

• What type of position you hold; 
• Whether your spouse or spousal equivalent at Deloitte will provide services to the restricted entity or its affiliates; and
• Whether or not you have an employee pension plan with, or
  investments (e.g. company shares) in, the restricted entity.

What is My Financial Provider Network (MFPN)?

MFPN is a network of over 30 leading financial providers that Deloitte has collaborated with to provide its people – and their Immediate Family Members (IFMs) – with a simplified way to maintain their independence records. Some providers offer discounted options for Deloitte individuals and their IFMs. 

Most Deloitte individuals* must use one of the MFPN providers when taking out a new investment. IFMs can opt to use MFPN also.

How does it work?

There are two offerings available – (1) an Automated Data Feed; or (2) the Pre-Cleared Investment Portfolio (DPIP). Each MFPN provider will offer one or both. 

1. Automated Data Feed: allows (the limited, relevant) information about your personal financial interests (e.g. shares, investments, funds) to be uploaded automatically from the providers systems directly into Deloitte Independence system called GIMS. This means you/your family member at Deloitte doesn’t need to manually input the information into GIMS each time an investment is bought or sold.

Updates to your investment information are received the next working day after any changes – so you’ll always meet the 10-day rule for recording investments on GIMS.

2. Deloitte Pre-Cleared Investment Portfolio (DPIP): The DPIP is a selection of investments that you can invest in worry free, with the comfort that your investments have already been pre-cleared by Deloitte for use by any Deloitte individual or their family members.
Deloitte’s Personal Independence team centrally monitor any restrictions associated with DPIP investments to ensure they remain permissible for individuals/family members to hold and removing the need for ongoing checks.

Data Privacy

Regulations require most Deloitte individuals* – and their Immediate Family Members – to record details of their financial investments in Deloitte’s compliance system (GIMS).

The information recorded in GIMS is limited to 2 fields: (i) the name of the account / wrapper (e.g. ISA, General Investment Account, pension) and (ii) the name of the underlying investments held in that account or wrapper (e.g. shares in ABC Limited). No other information – e.g. value of your investments – can or will be recorded in GIMS.

Information can be updated in GIMS manually. However, if you use MFPN, information will be updated in GIMS automatically. 

If you use an MFPN provider with an Automated Data Feed, the data files are encrypted, transferred via Secure File Transfer Protocol and accessible only to a small team subject to enhanced confidentiality procedures – to ensure the data is protected. 

*All Deloitte Partners and staff with a GIMS account.

Where can I find out more and sign up?

To find out more, including how to sign up, please contact Deloitte’s Personal Independence team via email or call 020 7007 7777, selecting option 4. 

Please note the email address above is for use by external (non-Deloitte) email addresses only. Individuals with Deloitte email addresses should not use this email address and should instead raise a ticket via My Support for any queries.

Deloitte’s independence can be impacted by financial arrangements and employment relationships of individuals at Deloitte – and their IFMs. We therefore need you to take some small but important actions that will help us remain independent and compliant with regulations. 

We don’t want this to be a burden on you or your family member at Deloitte, but this is an important regulatory requirement. 

Your family member at Deloitte receives regular training and communication on this subject – but we know that you don’t! 

So we have created the resources below to help you:

• understand the things you need to consider;
• understand the step(s) you need to take; and
• the practicalities of how/when to take the relevant steps.

Explore our resources for Spouses and Spousal Equivalents and those who are about to live together or get married.

Deloitte’s independence can be impacted by financial arrangements and employment relationships of individuals at Deloitte – and  their IFMs. We therefore need you to take some small but important actions that will help us remain independent and compliant with regulations.

We don’t want this to be a burden on you or your family member at Deloitte, but this is an important regulatory requirement.

Your family member at  Deloitte receives regular  training and communication on this subject – but we know that you don’t! So we have created the resources below to help you:

• understand the things you need to
  consider;
• understand the step(s) you need to take; and
• the practicalities of how/when to take the relevant steps.

Does your parent or guardian work at Deloitte? Use this flowchart to identify any actions you may have.
 

Further information for financial dependents.

The Deloitte Personal Independence team have hosted webinars specifically for Immediate Family Members (i.e. those outside of Deloitte), to give you an opportunity to hear directly how independence rules may impact you.

Please click the link below to access a recorded version of the webinar (17 minutes).

If you require further assistance or have questions after watching this video, you can speak to the Deloitte Personal Independence team directly via the details provided at the end of the recording (or the ‘Who can I contact?’ tile on this site).

If you’d like some more information, you may want to speak with your family member in Deloitte first and foremost. They have access to the Deloitte systems and should be familiar with Independence requirements if you want to discuss.

However, if you’d like to speak with someone else please contact Deloitte’s Independence team:

• Email us. Please note this email address is for use by external (non-Deloitte) email addresses only. Individuals with Deloitte email addresses should not use this email address and should instead raise a ticket via My Support for any queries.
• Call us on 020 7007 7777, selecting option 4