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KPMG’s independence systems, policies, and

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procedures are critical to as our System of Quality Control,

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also referred to our System of Quality Management.

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Key independence systems include Sentinel, KICS – ‘KPMG’s

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Independence Compliance System’, and the REL - ‘Restricted

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Entity List’. These systems help us maintain independence by

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preventing and detecting independence violations.

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Sentinel is the primary system used to determine if a

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proposed engagement or business relationship complies with

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applicable professional and regulatory standards. But its

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effectiveness is dependent upon entering complete and

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accurate data. Companies are constantly shifting, growing

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and restructuring, so we must stay ahead of transactions or

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activities that could result in new affiliates or affiliated

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persons. Audit engagement teams need to continually update

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the client’s Sentinel family tree in a timely manner to help

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ensure accurate placement of entities and affiliated persons

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on the tree, so all services and relationships can be

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evaluated appropriately, and the firm’s System of Quality

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Control can operate as intended. Teams also need to submit

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complete and accurate Sentinel requests so that Sentinel

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Lead Partners can appropriately evaluate the request.

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Getting tree maintenance, submittal and review right all are

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equally important in maintaining the system’s integrity, to

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avoid potential violations.

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The REL and KICS are additional tools that are important to

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our System of Quality Control. Restricting an entity on the

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REL results in the entity identifying as restricted in KICS.

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All public audit clients and any of their public affiliates,

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including their debt and equity securities, need to be

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properly listed as restricted on the REL. Non-public

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affiliates that offer financial products must also be

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included. Engagement teams are required to regularly review

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and confirm that restrictions are appropriate and request

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necessary updates, assuring the REL’s accuracy, including

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evaluating if new affiliates meet the requirements for

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inclusion. If changes need to be made, teams must submit a

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REL Update Form, verifying all engagement details are

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accurate. It is crucial the REL is updated timely, as our

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professionals rely on this information to maintain their

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personal independence.

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Our System of Quality Control also includes the procedures

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performed by audit engagement teams and documented in the

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KPMG Clara workflow, or KCw. It’s important that the

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engagement profile is set up within KCw accurately during

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the planning phase, to enable the delivery of applicable

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independence procedures within the Independence module. When

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the audit engagement team indicates that there are

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transactions resulting in new affiliates, the New Affiliates

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screen within the KCw Independence module is activated with

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procedures that must be completed to assess independence in

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relation to the new affiliate. Completing independence

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procedures is essential to a quality audit, so it’s critical

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to plan enough time to perform and document each step. There

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is execution guidance in the KPMG Audit Execution Guide

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(KAEG) that aligns with each step in the Independence module

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to assist teams in appropriately completing the procedures.

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Lead audit engagement partners rely on the results of

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independence procedures and the firm’s System of Quality

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Control to support annual independence communications to the

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Audit Committee, as required by PCAOB Rule 3526. In

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situations where there’s been a violation (also known as a

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breach) during the audit or professional engagement period,

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these communications must be reviewed and approved by the

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Independence Group, a key control step, prior to

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communicating to the Audit Committee. Teams are encouraged

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to use the Audit Committee templates available on Alex to

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help with all required written communications.

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The systems, policies and procedures that underpin our

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System of Quality Control work together to help us maintain

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our independence, communicate related matters, deliver

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quality audits to our clients, and ultimately build trust in

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the capital markets.