CONTENT

Synopsis

DELOITTE Touche Tohmatsu Limited (DTTL) 1

Vision and Values | 1 ; History | 2 ; Structure | 3
Industry and Services | 6 ; Practices on Ethics | 11 ;
Independence | 15 ; Transparency | 20 ;
Deloitte University | 33

Navarro and Amper Co. 35

History | 34 ; Structure | ; Services and Industry | 35 ;
Employee as an Asset | 40 ; Practices on Ethics | 41 ;
Practices in Team Engagement | 45; Independence | 48 :
Safeguards | 49

Appendix
Global Code | ; Sea Code |
 I. Deloitte Touche Tohmatsu Limited
Deloitte Touche Tohmatsu Limited is a UK private company limited by guarantee. Deloitte is
a leading global provider of audit & assurance, consulting, financial advisory, risk advisory, tax
and related services.

Deloitte has more than 263,900 professionals at member firms (Deloitte Network) delivering
services in audit & assurance, tax, consulting, financial advisory, risk advisory, and related
services in more than 150 countries and territorie serves four out of five Fortune Global 500®
companies. Revenues for fiscal year 2017 were US$38.8 billion.

A. Vision and Values

Vision
To be the Standard of Excellence, the first choice of the most sought-after clients and talent.

Purpose Statement
Making an impact that matters.
 Serve clients with quality and distinction, making measurable and attributable impact.
 Inspire people to deliver value---mentoring and developing future leaders and colleagues
for life.
 Contribute to the society, building confidence and trust, upholding integrity and
supporting the community
 Leading the profession by challenging ourselves to do what matters most, delivering
innovative ideas that reflect unique capabilities.

Values

Integrity
Deloitte believes that nothing is more important than reputation, and behaving with the highest
level of integrity demonstrating a strong commitment to sustainability, responsible business
practice.

Outstanding value to markets and clients

Deloitte plays a critical role in helping both the capital markets and clients operate more
effectively. The company considers this role a privilege, and know that it requires constant
vigilance and unrelenting commitment.

Commitment to each other

The company believes that culture of borderless collegiality is a competitive advantage and are
committed to nurturing it and preserving it going to extraordinary lengths to support our people.

Strength from cultural diversity

Clients’ business challenges are complex and benefit from multidimensional thinking. Deloitte
believes that working with people of different backgrounds, cultures, and thinking styles helps
people grow into better professionals and leaders.

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b. HISTORY
Opening of its first
1845 office in London, UK

Partnered with 1857

Thomas Greenwood

Deloitte opened its

1880 first office in New
York

Establishment of 1895
Haskins and Sells

George Touché
1898 established his own
firm in London

Deloitte first
collaborated with
1905
Haskins & Sells

George Touche opened

1911 Touche Niven & Co. in
New York City

Deloitte was essential in

convincing the audit of 1933
public companies
George Bailey
1947 founded his own
organization

Establishment of
Deloitte Haskins & 1952 The merger between
Sells Bailey, Touche Niven
1960 and Smart was
renamed Tocue,
Ross, Bailey & Smart

Establishment of
Tohmatso Aoki & 1968
Touche, Ross, Bailey
Co. & Smart was
1969 renamed to Touche
Ross
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 Tohmatsu became a part
1975 of Touche Ross

Merger
betweenDeloitte 1989
Haskins & Sells with
Touche Ross.
Renamed Deloitte
1993 Touche Tohmatsu

Creation of Deloitte 1995

& Touche
Consulting Group

2003 Deloitte refreshed its

brand

Deloitte updated its

logo

Creation of Deloitte
Intelligence 2007

Purchased North
2009 American Public
Service practice of
BearingPoint
Recombinant 2013
by Deloitte was
launched

C. STRUCTURE

Each member firm of its ‘global network’ is a separate and independent legal entity, subject
to the laws and regulations of the countries in which each of the member firms operate.
This structure is similar to other professional service networks that seeks to limit liabilities
for acts done by other members. Being separate legal entities, the members and DTTL cannot
obligate each other and are not liable for the negligence of other independent member firms.
The Deloitte network structure allows the member firms to be a leader at all levels-locally,
nationally, and globally-because its central governance policies are sensitive to the environment

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and culture of each individual country.
This kind of structure reflects the fact that the member firms are not subsidiaries or branches
of the global parent. They are separate and distinct locally formed legal entities that have
voluntary joined the network.
Member firms have access to the skills and knowledge of other member firms, can consult
with the Deloitte network, and can benefit from the network's market recognition and reputation.
The partners of the member firms are the sole owners of their respective firms. These firms have
come together to practice under a common brand, methodologies, and other professional
standards and guidelines.

Deloitte member firms support and adhere to the purposes and policies of Deloitte Global by:
 Conducting themselves in a manner that sustains the reputation of the Deloitte
Network;
 Aligning national plans, strategies and operations with those of Deloitte Global, as
appropriate, in consultation with Deloitte Global’s executive management
 Adhering to Deloitte Global’s requirements regarding professional standards, shared
valued, methodologies and system of quality control and risk; and
 Advising Deloitte Global of proposed joint ventures, joint practices, mergers and
other cooperation arrangements and combinations of any type with other member
firms.
Deloitte operates in more than 150 locations in different countries across three main regions,
namely Americas, Asia Pacific, and EMEA (Europe, Middle East, and Africa).
In some areas around the globe, member firms of Deloitte have formed key groups which
enabled them to enhance their cooperation and integrate standards common to all members. Some
examples of these key groups are Deloitte Americas, Commonwealth of Independent States
(CIS), Deloitte Middle East and Deloitte Southeast Asia (SEA).

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 ● The Board of Partners is responsible for promotion and protection of partner
interest, oversight of management, determination of long-term strategies, and the
oversight of risk and quality.
● The Executive Group assists the senior partner and chief executive in managing the
firm, implements the firm’s policies and strategies, planning for the firm’s future
development, and manage the day-to-day operations of the firm.
● The Audit and Risk Committee monitors the effectiveness of the firm’s internal
control and risk management systems, internal audit function, independence of the
statutory auditor, review and approval of the Transparency report, etc.
● The Public Interest Oversight Committee oversees public interest matters as they
affect the firm. Comprised of three Independent Non-Executives
● The Compensation Committee makes observations with regards to the proposed
assignment of equity groups and the allocation of profit sharing units of partners
who are members of the Board.
● The Remuneration Committee makes recommendations with regards to the proposed
assignment of equity groups and allocation of profit sharing units to the Chairman,
the Senior Partner, Chief Executive Officer and other holders of senior management
appointment as the Board may have determined.
● The Nomination Committee oversees the selection of candidates to stand in the Board
elections.
● The Responsible Business Committee is responsible for the UK firm’s responsible
business strategy, responsible business plans, monitoring performance against those
plans, oversight of management in the implementation and delivery of responsible
business strategies, and Deloitte’s charitable and philanthropic activities.
 The Transaction Sub-committee considers any transaction of the firm on behalf of the
Board.

Deloitte follows a hierarchical order in the career progress of their employees. At the
top level of the career chart at Deloitte is the Partner or Associate Partner. They are not
only the head of operations but they also lead the decision making process in the company.
The Senior Manager is the head of the administrative branch of the firm and he/she
also
ensures that the activities and operations of the firm are well managed and properly carried
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out.

The manager is directly under the Senior

Manager and is usually delegated to execute
administrative duties throughout their designated
field or department.
The Senior Consultant and Consultant are both
positions that deals with client and client based
projects. The Senior Consultant makes sure that the
project is met within the budget and time constraints
while the consultant is usually tasked with directly
engaging the clients.
The analyst is the entry level point of Deloitte
and is usually tasked to handle accounts, analyze
information and make reports.

D. INDUSTRIES & SERVICES

Industries

1. Consumer and Industrial Products

The UK C&IP group provides integrated services to clients across the entire value
chain, from raw materials to the end consumer. C&IP brings together the
knowledge of Consumer Businesses, Manufacturing and Business and Professional
Services experts throughout the Deloitte UK network.

● Automotive Deloitte’s Automotive sector

Practice helps companies, including original equipment manufacturers,
suppliers, dealers, aftermarket or finance companies, execute
good ideas in exceptional ways.

● Consumer Products
Deloitte’s Consumer Products specialists combine deep industry experience
and understanding of regional markets to help companies around the world
succeed wherever they operate.

● Industrial Products and Services

With extensive experience on Industrials Products & Services companies
around the world, Deloitte’s dedicated industry specialists provide
comprehensive, integrated solutions to address the unique challenges facing
our clients.
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 ● Travel, Hospitality and Services
Deloitte helps Travel, Hospitality & Services companies respond to the
challenges of an increasingly multi-channel environment, where the options
are many and customer loyalty is at a premium – and to grow in spite of all
these challenges.

2. Life Sciences and Healthcare

The Life Sciences & Healthcare industry group strives to support clients in
addressing the challenges that impact today’s industry.

● Health Care
Deloitte’s Health Care practice helps clients respond to the complexities of
today and tomorrow as they adapt their business models to new realities.

● Life Sciences
Deloitte understands the complexity that Life Sciences companies face in
pursuing innovative solutions to address today's challenges, and works with
them to drive progress and bring discoveries to life.

3. Technology, Media and Telecommunications

Deloitte’s Technology, Media & Telecommunications (TMT) industry group
brings together more than 15,000 professionals across 48 countries, serving over
90% of world’s most recognised TMT brands in the Fortune Global 500, and
helping companies of all shapes and sizes thrive in a digital world.

● Technology
Deloitte’s Technology practice focuses on helping companies of all shapes
and sizes deal with the demands of adapting their business strategies to
succeed in a rapidly changing technological landscape.

● Media and Entertainment

Deloitte helps Media companies respond to the challenges of an
increasingly multi-channel environment, where the options are many and
customer loyalty is at a premium – and to grow in spite of all these
challenges.

● Telecommunication
Combining a global network, innovative solutions and deep industry
practice, Deloitte’s Telecommunications sector helps clients navigate the
rapidly evolving landscape.

4. Energy and Resources

Deloitte’s Global Energy & Resources specialists provide comprehensive,
integrated solutions to several segments, offering clients exceptionally detailed
industry knowledge and a global network, alongside local market delivery.

● Mining
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 Deloitte’s global mining team offers unrivalled depth, breadth and quality
of expertise in mining. With an established international network of
professionals, we offer a global, integrated approach combined with
business and industry knowledge to help our clients excel anywhere in the
world.

● Oil and Gas

Deloitte’s Oil & Gas professionals work with clients to maximise their
potential across the full spectrum of the sector – from super majors and
trading businesses to independents – to deliver services, perspectives and
solutions that best suit the business and its people.

● Shipping and Ports

Deloitte’s Shipping & Ports team provides advice and services to the water
transportation industry. They have an established track record in the sector
and offer real value by combining specialist skills with market knowledge
to help clients at all stages of their business development.

5. Public Sector
Deloitte Global Public Sector is committed to improving public outcomes through
a focus on people. Deloitte member firms think about the complex issues facing
the public sector and develop relevant, timely, and sustainable solutions for our
clients. At Deloitte, we are Thinking people.

● Civil Government
Deloitte’s Civil Government practice provides solutions to help
communities operate efficiently and effectively across a wide range of
programmes, from health to education and transportation.

6. Financial Services
Deloitte’s financial services industry specialists provide comprehensive, integrated
solutions to the banking & securities, insurance, and investment management
sectors. Deloitte member firms’ breadth of services and industry knowledge allow
us to understand each client’s unique business needs.

● Banking and Securities

From regulatory reform to technological complexity, competitive
dynamics, and market moves, Deloitte’s Banking & Securities practice
brings together professionals with diverse experiences and knowledge to
provide customised solutions for our clients.

● Insurance
Deloitte’s Insurance practice helps clients improve profitability while
balancing the demands of regulatory change and shifting customer
expectations.

● Investment Management
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 Deloitte’s Investment Management practice helps clients across the sector –
including private equity, hedge funds and mutual funds – rise to the
challenges of a complex marketplace and capitalise on opportunities in an
ever-changing global landscape.

● Real Estate
Deloitte has extensive experience serving Real Estate companies operating
in mature and emerging markets around the world. Our dedicated
specialists provide comprehensive, integrated solutions to address the
unique challenges facing our clients.

Services

1. Audit and Assurance

Audit attests accomplishment and challenges to help assure strong foundations for
future objectives and goals. Deloitte answers the what, how, and why of change
so the company will be ready to act in the future. In auditing, Deloitte uses an
integrated approach that fits to the client’s industry as well as employ leading-
edge support tools.

2. Consulting
Being one of the largest management consultancy globally, Deloitte offers global
experience and local knowledge to influence the impact on the current issues
faced by the client and anticipating any issues that may arise in the future.
Deloitte has a senior team of professionals who have a perfect blend of executive
and hands-on experience which are complemented by the deep understanding of
industries both at local & regional level.

 Human Capital
Having expertise in HR Strategy, organization and change, high
performance cultures and rewards, the consultants may identify, manage
and solve human capital issues that enables the business to perform above
potential.

 Strategy and Operations

The consultants may assist the clients to identify and prioritize areas that
contributes in the growth of business. The consultants may also assist in
identifying market opportunities, enhance sales and service management
and process efficiency. Deloitte’s expertise covers key areas such as
organizational design, right-shaping and right-sizing, analysis and
definition of capabilities, roles and responsibilities, motivation, incentives
and compensation, learning and development.

 Technology
Deloitte offers services such as supporting business and IT alignment,
definition of IT strategy and governance, cost analysis and optimization,
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 requirements management and purchasing support for key applications.

3. Financial Advisory
Deloitte offers financial advisory services which combines the international best
practices and knowledge to fit the local market conditions. Deloitte also offers a
comprehensive range of multidisciplinary advisory capabilities to the clients,
including corporate finance, transaction support, valuation, finance raising, tax
structuring and planning, and corporate restructuring.

● Acquisition and Merger

In acquisitions, Deloitte aims to minimize the risks related to the
acquisition by providing advices on planning, targeting and execution.
They also assists clients in the formulation of the approach strategy,
valuation and financial structuring, negotiations of deals, gives advices on
auction tactics, preparation of public documents and to ensure a timely and
managed completion in both acquisition and merger.
4. Tax
Deloitte combines the insight and innovation from multiple tax areas with
business and industry knowledge to make the client excel locally and globally.
Their services cover both the implications of the client’s tax requirements locally
and internationally.
 Global Employer Services
Deloitte offers well-structured plans and development strategies that can
streamline local or global compensation programs from a tax and social
security perspective. The team may also assist the client in handling
employees’ international mobility aspects such as mobility planning,
immigration process, coordination of expatriates’ programs, salary and
personal tax compliance, assistance in obtaining social security certificates
of coverage, etc.
 Indirect Tax
Deloitte’s indirect experts are well-informed and understands well the
regulations, the depth of industry knowledge and the continuing growth in
the role of technology.

 Global Business Tax Services

Deloitte may assist the client develop and implement global tax strategies
in order to maximize business development and to optimize the tax impact
of the transactions, irrespective of the locations of the activities. By using
the local and global resources through the international network, Deloitte
may develop an overall tax strategy depending on the needs and
expectations of the client and simplify tax management.

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5. Risk Advisory
Risk Advisory Services assists the clients in the assessment of enterprise risks and
its management and control. The aim of risk advisory service is to review the
client’s current processes and identify any areas where risk management can be
improved depending on the type of the client’s business.

 Strategic and Reputation Risk

Deloitte, in order to help protect the reputation the the client company,
helps organization make risk-informed strategic decisions and provide
assistance in the formulation of response to the disruptions of the growth of
the businesses.

 Regulatory Risk
Deloitte helps organisations expect and adapt to changes in the regulatory
environment, and build better programs and controls to address the wide
variety of regulations and regulatory risks. Since organizations must meet
the demands of the complex regulatory framework, organizations must also
assure that their regulatory program is flexible enough to be industry-focus.

 Financial Risk
Deloitte helps organisations through the full life cycle of financial
transactions. From governance and processes to technology and reporting,
the services can enhance transparency, efficiency, compliance, and
financial integrity.

 Operational Risk
Deloitte may assist the organizations transform the ways they influence
people, third-party relationships, technology, data, business processes, and
controls to manage operational risks and raise business performance.
Optimized business decisions are a product of the integrated, strategically-
aligned operational risk management solutions.

 Cyber Risk
Deloitte may assist the organizations in the prevention of cyber attacks and
protection of valuable assets. We believe in being secure, vigilant, and
resilient - not only by looking at how to prevent and respond to attacks, but
at how to manage cyber risk in a way that allows the client company
unleash new opportunities.

6. Private Companies
Deloitte may assist in the formulation of solutions to address the challenges which
are unique in different private companies, family businesses and entrepreneurs.
They may also provide insights about the challenges faced.

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E. Practices on Ethics

Global Priniciples of Business Conduct or Global Code

The Global Code are standards that outline the commitments that each of key players of
the organization make. It is based on its shared values and reflects its core belief that, at Deloitte,
ethics and integrity are fundamental and are not negotiable.

Who are covered by the Global Code?

This Global Code applies across the Deloitte network and provides the foundation for how
its people behave. Each member firm in the Deloitte network commits to the Global Code and, as
appropriate, builds on it through more detailed codes of conduct.
In addition to local codes, the Global Code is supplemented by member firm ethics
programs which provide support to build ethical judgment and decision-making skills in all
Deloitte people.
Duties of the parties, professional staff and support staff
1. Duty to know, understand and comply
Acting in accordance with the Global Code is a responsibility for all the people at
Deloitte. Everybody in the organization is called upon to know, understand and comply with it.
Moreover, all of its employed professionals have a responsibility to raise their voice when they
become aware of anything that is inconsistent with it.
2. Duty to consult
Consultation goes to the heart of the Deloitte culture, and avoids its people having to
resolve a difficult ethical situation alone. Individuals are encouraged to consult with their
colleagues, line managers, leaders or their member firm’s normal reporting channels. In addition,
formal ethics reporting channels are available for those who seek a confidential route for
consultation.

Parts of the Global Code

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The code is divided into three parts which corresponds to the parties which the organization
continues to seek to make an impact that matters to, namely:

 The clients.
Commit to serve clients with distinction.

Integrity
• Straightforward and honest in professional opinions and business relationships.
• Truthful about the services provided, the knowledge possessed, and the experience
gained.

Quality
• Committed in providing quality services by bringing together the breadth and depth of the
resources, experience and insights to help clients address their needs and problems.
• Strive to develop outcomes that create an impact that matters for the clients.

Professional behaviour
• Comply with applicable professional standards, laws and regulations and seek to avoid
actions that may discredit the company or profession.
• Foster a culture of appropriate professional scepticism and personal accountability, which
supports clients and drives quality in the services provided.
• Understand the broader impact that the work has on society, on people, and on clients,
and conduct business with those interests in mind.
• Committed to earning and sustaining the public’s trust and confidence in the work done.

Objectivity
• Objective in forming professional opinions and the advice given.
• Do not allow bias, conflict of interest, or inappropriate influence of others to override
professional judgments and responsibilities.

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 • Do not offer, accept or solicit any gifts, entertainment or hospitality that we have reason
to believe may be intended to improperly influence business decisions or impair
objectivity.

Competence
• Use due care to match client needs with practitioners who have the competence required
for their assignments.
• Foster innovation and new ideas to improve the value and performance of the company’s
services.

Fair business practices

• Respect competitors and are committed to fair business practices.
• Receive fees that reflect the value of services provided and responsibilities assumed

Confidentiality, privacy and data protection

• Protect and take measures to safeguard the confidential and personal information that the
company hold, collecting and handling it in compliance with applicable laws,
professional obligations, and its own data management policies and practices.
• Prohibit disclosure of confidential and personal information entrusted unless granted
permission or there is a legal or professional right or duty to disclose.
• Prohibit the use of confidential information about clients for personal advantage or for the
benefit of third parties.

 The Employees.
Commit to inspire talented professionals to deliver outstanding value

Respect, diversity and fair treatment

• Foster a culture and working environment where the people treat each other with respect,
courtesy and fairness, promoting equal opportunity for all.
• Encourage and value a diverse mix of people, viewpoints, talents, and experiences.
• Create inclusive working environments that not only address individual needs, but allow
people to utilize their unique strengths.
• Do not tolerate harassment or unfair discrimination in its working environments

Professional development and support

• Invest in its people to develop the professional knowledge and skills necessary for them
to effectively perform their roles.
• Help them reach their potential through investments in personal and professional
development and support programs.
• Provide a safe work environment for its people and expect clients to do the same.

 The Community
Commit to contribute to society as a role model for positive change.

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Anti-corruption
• Are against corruption and neither make bribes nor accept them, nor induce or permit any
other party to make or receive bribes on the company’s behalf.
• Support efforts to eradicate corruption and financial crime.

Responsible supply chain

• Do not condone illegal or unethical behaviour by suppliers, contractors and alliance
partners.
• Select suppliers through fair procurement processes.

Social responsibility
• Contribute to society and communities by engaging with non-profit organizations,
governments, and other businesses to make a positive impact on local, national or global
challenges.
• Support communities in a variety of ways, such as donating money, providing pro bono
client services and supporting the volunteering of time by our people.
• Support efforts to drive sustainable development and respect human rights standards.
• Recognize that the business operations and provision of services may at times impact the
environment and work to reduce harmful effects they might have.

F. INDEPENDENCE

Deloitte invest in systems and processes to safeguard the independence and objectivity of
the firm, its professionals and engagement teams, and avoid conflicts of interest in
engagements.
The engagement take-on, continuance, compliance, audit appointment and client database
tools are all internally developed and comprise solutions to address the complexity of
global regulatory requirements. The tools are designed to be intuitive, while facilitating
timely compliance, reporting and monitoring, and to ensure that we (including our partners,
professionals and any of their close connections) do not engage in certain transactions or
relationships with any entities from which we are required to maintain independence
(restricted entities).

The main systems and processes of internal control in this area are:

 Conflicting checking system

Identifies and manages potential conflicts in respect of proposed engagements,

business and financial relationships.
The conflict check system automatically searches the Restricted Entities Database
to identify whether any of the relevant entities are restricted. Where they are, the
conflict check response will require consultation with the relevant partners to
confirm that the proposed engagement, business or financial relationship will not
impair independence.
Such confirmation and relevant approvals must be obtained prior to acceptance.

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  Restricted entities database
Records comprehensive details on every restricted entity allowing partners and
staff to check independence requirements for any type of investment or product
before they enter into any financial relationship. It is also used as part of the
engagement acceptance procedures to identify restricted entities and ensure that
proposed services are subject to the appropriate approvals.

 Annual Returns

Obtains confirmation from partners, professionals and support staff, upon joining
the firm and on an annual basis thereafter, that they are aware of restricted entity
policies and that they are not engaged in any restricted transactions or business
relationships.

 Personal Connection Systems

Enables us to monitor the financial interests of all partners and client-facing staff
of manager grade and above. Individuals are required to record their, and their
immediate family members’, financial interests. The system interfaces with the
Restricted Entities Database to alert the individual if a new or existing connection
is with a restricted entity and prescribes what action the individual needs to take.

 Inspection & Testing

Assessment of the financial holdings of a sample of partners and client facing staff
of manager grade and above is carried out each year by a dedicated team.
Inspection & Testing is an in-depth review of an individual’s, and their immediate
family members’, financial holdings and business relationships, including those
financial interests previously disclosed to the firm through their Personal
Connections record and those identified using third party documentary evidence.

 Business relationships monitoring system

Records all business relationships and alliances of the firm. A dedicated team
independently reviews any proposed business relationship and ensures that any
proposed relationships with restricted entities are subject to the appropriate
approvals.

 Client due diligence system

Part of our client/engagement take-on process, as required by our anti-money
laundering procedures, which includes a link with the conflict check system, risk
assessment and partner engagement acceptance approvals.
Note: If any queries arise as a result of any of these areas, dedicated support is provided through
our Quality & Risk Management teams. Additionally, on independence related matters staff may
consult with Deloitte Global’s independence group if they determine that the circumstances
require global input or advice. Where it is determined that it is not possible to sufficiently mitigate
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the independence risk identified, the proposed engagement or relationship will be declined.
(same2 siyag approach sa COE katong gibasa nato)

Raising Awareness

2016/17 awareness programme included such items as:

1. Updates to internal policy and guidance to reflect and raise awareness of the FRC
Revised Ethical Standard.
2. Further communication, presentations and live training to professional staff on the new
independence rules and the impact on individuals and client relationships, through close
collaboration with all Service Line Quality and Risk teams.
3. Implementation of an independence pre-clearance process for audit professional staff
prior to joining the firm, helping to identify any potential independence concerns in a
timely manner and working with the individual to implement appropriate actions.
4. One-to-one consultations with partners retiring from the firm to advise them of future
independence considerations.
5. Tailored communications to individuals where the restrictions on their connections have
changed due to a new audit.
6. Targeted communications to Personal Connections users on reporting requirements.
7. Firmwide communication reminding staff of the independence requirements, including
new case studies to bring independence to life, and information on the enhancement of
the firm’s policy on instances of non-compliance.

Provision of the revised Code

A. Leadership
Owner accountability principle
The management of a firm should be accountable to the firm’s owners and no
individual should have unfettered powers of decision.
Management principle
A firm should have effective management which has responsibility and clear authority
for running the firm.

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B. Values
Professionalism principle
A firm should perform quality work by exercising judgement and upholding values of
integrity, objectivity, professional competence and due care, confidentiality and
professional behaviour in a way that properly takes the public interest into
consideration and meets auditing and ethical standards.
Governance principle
A firm should publicly commit itself to this Audit Firm Governance Code.
Openness principle
A firm should maintain a culture of openness which encourages people to consult and
share problems, knowledge and experience in order to achieve quality work in a way
that properly takes the public interest into consideration.
C. Independent Non-Executives (INEs)
Involvement of Independent Non-Executives principle
A firm should appoint Independent Non-Executives to the governance structure who
through their involvement collectively enhance the firm’s performance in meeting the
purpose of the Code.
Characteristics of Independent Non-Executives principle
The Independent Non-Executives’ duty of care is to the firm. They should command
the respect of the firm’s owners and collectively enhance shareholder confidence by
virtue of their independence, number, stature, experience and expertise. They should
have a balance of relevant skills and experience including of audit and a regulated
sector. At least one independent non-executive should have competence in accounting
and/or auditing, gained for example from a role on an audit committee, in a company’s
finance function, as an investor or at an audit firm.
Rights and responsibilities of Independent Non-Executives principle
Independent Non-Executives of a firm should have rights consistent with their role
including a right of access to relevant information and people to the extent permitted by
law or regulation, and a right to report a fundamental disagreement regarding the firm
to its owners and, where ultimately this cannot be resolved and the Independent Non-
Executive resigns, to report this resignation publicly.
D. Operations
Compliance principle
A firm should comply with professional standards and applicable legal and regulatory
requirements. Operations should be conducted in a way that promotes audit quality and

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 the reputation of the firm. The independent non-executives should be involved in the
oversight of operations.
Risk management principle
A firm should maintain a sound system of internal control and risk management over
the operations of the firm as a whole to safeguard the firm and reassure stakeholders
People management principle
A firm should apply policies and procedures for managing people across the whole firm
that support its commitment to the professionalism, openness and risk management
principles of this Audit Firm Governance Code
Whistleblowing principle
A firm should establish and apply confidential whistleblowing policies and procedures
across the firm which enable people to report, without fear, concerns about the firm’s
commitment to quality work and professional judgement and values in a way that
properly takes the public interest into consideration.
E. Reporting
Internal reporting principle
The management of a firm should ensure that members of its governance structures,
including owners and Independent Non-Executives, are supplied with information in a
timely manner and in a form and of a quality appropriate to enable them to discharge
their duties.
Governance reporting principle
A firm should publicly report how it has applied each of the principles of the Audit
Firm Governance Code and make a statement on its compliance with the Code’s
provisions or give a considered explanation for any non-compliance.
Transparency principle
A firm should publish on an annual basis in its transparency report a commentary on
the firm’s performance, position and prospects.
Reporting quality principle
A firm should establish formal and transparent arrangements for monitoring the quality
of external reporting and for maintaining an appropriate relationship with the firm’s
auditors.
Financial statements principle
A firm should publish audited financial statements prepared in accordance with a
recognised financial reporting framework such as International Financial Reporting

19 | P a g e
 Standards or UK GAAP and should be clear and concise.
F. Dialogue
Firm dialogue principle
A firm should have dialogue with listed company shareholders, as well as listed
companies and their audit committees, about matters covered by this Audit Firm
Governance Code to enhance mutual communication and understanding and ensure that
it keeps in touch with shareholder opinion, issues and concerns.
Shareholder dialogue principle
Shareholders should have dialogue with audit firms to enhance mutual communication
and understanding.
Informed voting principle
Shareholders should have dialogue with listed companies on the process of
recommending the appointment and re-appointment of auditors and should make
considered use of votes in relation to such recommendations.

G. TRANSPARENCY REPORT

Deloitte recognises that the general level of trust in business has declined in recent years.
In providing robust, high quality audits and other business services, Deloitte is an important
contributor to, and enabler of, trust and confidence.
It strives to remain at the forefront of innovation in the profession and deliver solutions
every day that help our clients unlock possibilities and navigate complexities.

Deloitte must also remain a dynamic, diverse and inclusive place to work, open and
attractive to people from all backgrounds, and that we support our clients to do the same.
Inclusive behaviour and respect are expected of all our people and form a key part of our talent
strategy.

Blind recruitment

 Seeks to prevent unconscious bias and ensure that job offers are made on the basis of
present potential, not past personal circumstances; interviewers do not have access to
applicant’ school or university details until an offer has been made.

Contextualised Recruitment

 Provide recruiters with a range of standardised data on candidates’ economic backgrounds

and personal circumstances, allowing them to consider the context in which their
academic achievements have been gained.
 Prioritize the recruitment and retention of senior women.
20 | P a g e
  Black, Asian or from an ethnic minority (BAME)
 Women on Board
Deloitte priorities in Fiscal Year 2018

 Driving further improvements in audit quality

 Capitalising on the opportunities arising from North West Europe.
 Engaging proactively with regulators and other key stakeholders.
 Driving international consistency improvements and enhanced network
collaboration.
 Culture
 One Million Futures – to support and inspire a million people get to where they
want to be – in the classroom, workplace or board room.

Report from the Independent Non – Executives

 Primary responsibility is to help ensure that the public interest considerations are
central to Deloitte’s decision-making through being actively involved in
Deloitte’s supervisory and governance processes.
 The board usually meets every month for a whole day.
 Their duties are primarily fulfilled through our engagement as members of the
Board and its subcommittees, and by our interaction with partners and staff on
more informal occasions.
 They meet as members of the Public Interest Oversight Committee (PIOC)
 Meet with regulators, investor groups and representatives fro professional bodies
on a regular basis.

Audit Quality

Done in Four ways:

 Monitoring and assessing the firm’s audit transformation programme. It covers the
following:
 Audit approach
 Staff training and motivation
 Centres of excellence
 Delivery services
 Technology

 Involvement with the assessment of any audits which are being investigated by the
regulator or which otherwise do not meet the standard required; as well as helping to
ensure that the root cause analysis is comprehensive and rigorous, and that required
changes are introduced.

 Reviewing the results of internal and external audit inspections with the Audit
leadership team and external inspectors.
21 | P a g e
  Discussions with audit partners and staff to assess other issues such as the balance
between professionalism and commercialism, and workplace stress.
There is regular discussion at Board and other meetings about how the firm can protect and
enhance its reputation, in the UK and globally. The Board is kept informed about any global
reputational issues, with the global CEO and chairman attending meetings periodically.
The INEs see the Ethics Partner as members of the A&RC and review the firm’s ethics policies,
training and awareness raising. People management policies and procedures, whistleblowing, HR
and disciplinary reports are also reviewed by the INEs as members of the A&RC and/or the
Board.

Audit and Risk Committee

Comprised of five partners, all elected members of the UK Board, with the INEs and the firm’s
Chairman in attendance.

 The A&RC members, including the Chairman, were appointed by the UK Board.
 The A&RC met eight times during the year ended 31 May 2017 (FY16: six times).
 From 1 June 2017, a new A&RC has been created to operate at North West Europe
level with the UK Oversight Board being established to oversee specific aspects of
the management of the UK firm.
 Also considered the financial impact of forthcoming changes to accounting
standards, focusing on the impact of changes to the recognition of revenue and lease
accounting.
Deloitte monitored the provision of non-audit services and concluded that non-audit fees of
£18,500 (FY16: £18,000) for additional assurance over certain environmental performance data in
the Impact Report did not represent a threat to independence.

Quality and Risk

The A&RC considered reports from:

 The firm’s Managing Partner, Quality and Risk on any decisions taken by the firm’s
Executive Risk Committee that could materially affect the firm’s risk appetite.
 The firm’s Head of National Quality and Risk Management on the results of the
firm’s portfolio risk review.
 The firm’s Head of National Quality and Risk Management on the status of the
firm’s regulatory compliance, covering: Financial Conduct Authority compliance,
audit regulation and conduct, and other regulators (including ICAEW practice
assurance regime).
 The service line managing partners and quality and risk partners on the
management of quality and risk across the firm.
 The firm’s Money Laundering Reporting Officer, also the Anti-Bribery Officer,
with regard to the firm’s compliance with the Proceeds of Crime Act, Terrorism
22 | P a g e
 Act, Money Laundering Regulations, UK Bribery Act and financial sanctions
regime.

Risk Management and Internal Control

 The firm uses The FRC’s Guidance on Risk Management, Internal Control and
Related Financial and Business Reporting as a framework to maintain sound system
of internal control and risk management and in reviewing its effectiveness.

 In relation to the internal control environment, the firm conducts an annual review
of the effectiveness of the firm’s system of internal control, including financial,
operational and compliance controls and risk management systems as well as the
promotion of an appropriate culture underpinned by sound values and behaviour
within the firm.

Delivering Quality Audits

This is driven by:

 Culture

 Is an essential part of our business in engendering and preserving trust. This all
underpinned by placing quality and our people at the heart of everything we do.
 Ethics Code, work on respect and inclusion, and Deloitte leadership initiative
(which encourages leadership behaviour at all grades throughout the organization).
 Our approach to ethics seeks to build and embed a culture of quality and integrity
where people feel supported to raise their voice when something does not feel right.
 Is described through our firm’s purpose, values, strategy and competencies.
Examples of some desired behaviours and symbols supporting audit quality culture include:
i. Tone from the top
ii. Communications and learning
iii. Professional scepticism and integrity
iv. Protecting the firm’s interest

 Focus on Culture

New interactive ethics eLearning course, which provides real-life examples of

ethical challenges and practical problems, has been develop in 2017 and will be
rolled out this FY18.
Positive actions have been taken to strengthen the linkages between the firm’s
motivational and disciplinary systems and recruitment procedures so they align
with firm’s purpose, values, expected behaviours, strategy and desired audit
quality culture.
Note* Deloitte EXPECTS high standards of ALL its people, especially in relation to CONDUCT
& INTEGRITY. Where the behaviour of our partners and staff falls short of the standards

23 | P a g e
expected of them, it is dealt with through the firm’s investigation procedures and commensurate
action is taken.
 Evaluating and overseeing our culture
To help improve the culture of continuous learning across the firm, we use surveys,
key indicators and root cause analyses to measure and monitor people’s perception of
various audit quality culture influencers.

 People
Ensure that the professionals working in their audit engagements have the necessary
knowledge, capabilities, experience and competence to deliver work of the highest quality
and that they are appropriately supervised by skilled partners and managers.

 Recruitment
They have rigorous recruitment process, including skills assessments and
competency-based interviews.

 Measuring and rewarding audit quality performance

They create an environment where achieving high quality is valued, invested in and
rewarded.

Each audit partner and signing director:

i. Receives an annual audit quality dashboard recording a variety of audit

quality metrics, covering matters such as internal and external audit
quality, Corporate Reporting Review Panel findings, personal
independence, appraisal documentation and audit compliance.
ii. Receives an audit responsibility rating, reflecting the level of risk,
complexity and public scrutiny they should in their roles, including as
Engagement Quality Control Reviewer, on audit engagements.
iii. Levels of responsibility and Required performance on an audit
engagement key drivers in the reward and promotion of our audit partner
and staff.

 Learning programs
 Continuing professional development is based around targeted learning
programmes, including regular audit, accounting and industry-specific
training to keep all of our professionals at the forefront of new developments
and regulations.
 Experienced partners and technical experts lead the delivery of the course,
seeking to ensure consistency, quality and maximum impact.
 The company run regular Essential Professional Updates for audit
professionals, which cover current and emerging audit and accounting
matters.

All qualified audit professionals are required to attend

i. annual technical update training
24 | P a g e
 ii. a residential course covering audit
iii. accounting and other matters such as professional skepticism
iv. audit tools and project management.

 Systems and processes

 Audit methodology and software

 The Deloitte Audit Approach Methodologies are designed centrally by the

company’s global team (to which all member firms contribute) and then
tailored to comply with all UK professional standards and legal and
regulatory requirements.
 They continue to enhance their audit methodologies across all the member
firms in their network to encourage a more robust, fact-based risk assessment
and varying their audit response as a result of that risk assessment.

 Use of specialists and experts

 Deloitte involve experts who are not part of the core audit team throughout
their audit work.
 Their specialist auditors, including tax, IT, actuarial and valuations
specialists, as well as their centers of excellence for impairment and pensions
receive annual audit training and work directly within their audit systems.

 Audit project management and timing

 Deloitte’s audit milestones programme provides guidance to teams on
objective completion dates for key activities.
 Milestones programme must be followed for their larger audits, and is
strongly recommended for smaller engagements.

 Audit reporting
 Deloitte believe that high quality, insightful audit reports must be carefully
tailored to the entity and be clear and unambiguous.
 All of their enhanced audit reports are reviewed by their Enhanced Auditor
Reporting Panel to consider the appropriateness and clarity of the report.
 They established the Quality Corporate Reporting Centre to assist their
people in dealing with increasing complexity around financial reporting.
 Effective, clear and timely communication with audit committees, and with
others charged with governance, is also key to the quality of their audits.
 Deloitte aim to continually improve the quality of such reporting, including
enhancing the clarity of their explanations of the audit process.

 Engagement Quality Control Review

 For public interest entities, an independent engagement quality control
review (EQCR) partner has responsibility for the whole of an engagement’s
EQCR process, supported by Professional Standards Review (PSR),

25 | P a g e
 together with other specialist support as deemed necessary.
 All engagements, where the team is considering issuing a modified audit
opinion, are subject to an additional level of independent review by the
Centre of Excellence for Modified Opinions.

 Causal factor analysis

The scope of causal factor analysis includes:

 Engagements receiving adverse ratings in regulatory or internal inspections.
 Selected findings arising from inspections of the company’s system of
quality control.
 Recurring findings across a number of engagements or areas, regardless of
inspection outcome.
 A selection of their highest quality audits assessed during inspections and
selected examples of good practice.
 Other quality matters including a selection of first year audits and prior
period adjustments.

The causal factor process involves a detailed analysis of the audit work in the
area of the finding or good practice, review of relevant technical guidance and
learning materials, an analysis of relevant audit quality indicators and
interviews with key engagement personnel who were responsible for the
preparation or review of the relevant area.

 Audit quality structures

 Audit Quality Board (AQB) - Its remit is to:

o Develop and govern activities that will achieve sustainable
improvements in audit quality
o Implement these improvements across the audit practice
o Respond to audit quality issues raised by regulators and stakeholders,
including the FRC’s Audit Quality Review (AQR) team, the ICAEW’s
Quality Assurance Department (QAD) and the US Public Company
Accounting Oversight Board (PCAOB)
o The AQB meets quarterly and actions driven by the AQB during the
year include the matters covered in this section of the report,
specifically:
-Outcomes from external and internal inspections
-Strategic responses to the underlying causes of inspection
findings
-Further enhancement of the content and delivery of their learning
curriculum
-Improving the challenge from their Engagement Quality Control
Reviewers
-Identifying priorities and creating a formal Audit Quality Plan
for 2018

26 | P a g e
  Audit Quality Forum
o The AQB established an Audit Quality Forum in 2015, comprising
junior staff from associate to manager grades, to give a voice to people
at different stages of their careers to further improve audit quality. The
forum meets four times a year.
o The chairperson of the forum sits on the AQB to feed back results for
further action, as necessary
 Emerging Issues Group (EIG)
o EIG’s objective is to identify significant emerging industry,
political/economic, technology and regulatory/inspection related issues
that could have a significant impact on audit quality in the future.
o The EIG drives the development of actions to address these matters,
working with Industry Groups, NAA and the network of Audit Quality
Leaders who are embedded in the audit groups. The EIG reports
directly to the Audit Executive.

 Global consistency

 Global links

 Deloitte serve many global clients and focus on providing consistent, quality
audits across the whole of their international network.
 Deloitte work closely with their Deloitte Global colleagues and with those in
other member firms in the Deloitte Network to achieve this.

Deloitte’s actions to enhance audit quality on PCAOB engagements have

included:
o The introduction and local implementation of a global PCAOB audit
approach manual, in addition to their separate audit approach manual
for International Auditing Standards.
o The introduction of internal inspections designed to replicate a
PCAOB inspection, both in the style of the review and in the
consequences of the results of the inspection.
o Deployment of a new learning syllabus focused on PCAOB
requirements, for all staff working on PCAOB engagements.
o Appointment of a partner responsible for PCAOB audit quality and
risk and the development of specific support within the UK team for
PCAOB audits.
o Using professionals from the GCoE to provide support to engagement
teams working on PCAOB engagements in preparing for an effective
audit.
o Distributing global communications about the latest PCAOB auditing
guidance and hot topics so that all relevant people in the global
network receive the same information at the same time.

 Global audit imperatives

27 | P a g e
  The Deloitte Network’s aim is to drive professional excellence through the
consistent global application of eight audit imperatives, which have been
adopted by every member firm.
o Remain objective and sceptical throughout the audit – challenge areas
involving management judgement or transactions outside the normal
course of business.
o Obtain a thorough understanding of process flows for significant
accounts and related disclosures. Identify relevant controls, evaluate
their design, determine their implementation and, when applicable,
including for PCAOB audits, sufficiently test relevant controls.
o Develop and execute a comprehensive audit project plan to optimise
timing of procedures throughout the audit cycle and innovate audit
service delivery.
o Apply expertise in areas involving specialists through the tailoring of
audit responses specific to the entity.
o Remain resolute on directing, supervising and reviewing the work of
component auditors.
o Advance professional development through enriching your skillset and
the skillset of others.
o Perform robust risk assessment procedures to appropriately identify and
assess the risks of material misstatement and design and execute further
audit procedures to respond to the identified risks.
o We all own quality – individually and together.

 Member firm group audits

 Deloitte Global issued additional guidance on how group auditors should
evaluate and supervise the work of Deloitte component auditors, which was
supplemented in the UK by an additional consultation requirement on
group audits where certain Deloitte Global member firms are involved.
 This seeks to ensure that audits fully comply with applicable auditing
standards throughout a wider group, wherever the other auditor is based,
and whether or not it is part of the Deloitte Global network

Measuring Quality

Internal inspection
At its core, the practice review programme determines whether the company have
complied, in all material respects, with the professional standards and the policies
contained in the Deloitte Policies Manual (DPM) and Audit Approach Manual (AAM), as
well as applicable professional standards and regulatory and legal requirements.

Wider than this however, it provides assurance over the level of quality delivered by a
Deloitte audit and drives the culture of continuous improvement. Within the practice
review programme there are two elements that work together to meet the overall aims:
 individual Engagement Review (ER) that primarily assesses compliance with the
28 | P a g e
 AAM,
 System of Quality Control (SQC) review that primarily focusses on the firm’s
internal processes to comply with the DPM.

Deloitte transformed practice review process includes the following key parts that ensure it is
delivered with the right level of scrutiny and rigour:

a. Selection process
A detailed selection process is undertaken each year for both the
engagements to be reviewed and the scope of work for the SQC.

b. Experienced reviewers
Across both the ER and SQC, we undertake a comprehensive selection
process, ensuring the Reviewers as a team have the relevant industry
and technical experience, quality record, seniority, and sufficient time
to be able to bring robust independent challenge.

Once selected, all Reviewers are given thorough training by the leaders
in their central team

c. Consistency of findings
At the end of each review, the findings are moderated centrally by a
moderation panel. This moderation panel applies a regulatory lens from
their library of inspection findings to ensure that findings are classified
consistently.

d. Action and ongoing education

The results of the practice review are communicated to the UK Audit &
Assurance Executive, the UK Risk & Reputation Leader, the A&RC
and the INES via their attendance at the A&RC.

External reviews

 FRC Audit Quality Thematic Reviews

 The FRC’s AQR team uses thematic reviews to supplement its annual
programme of audit inspections of individual firms.
 Firms’ policies and procedures are reviewed in respect of a specific aspect
of auditing to test their application in practice.
 Analyze further aspects of auditing which are not considered in detail
during their routine audit inspections.
 Seek to identify both good practice and areas of common weakness among
audit firms.

 Other overseas and offshore regulatory bodies

The firm is also subject to regulation by certain overseas regulators where we audit
entities listed on an exchange in their jurisdiction and we are registered with that
29 | P a g e
 regulator.

Audit Quality Indicators (AQIs)

 In 2014 the six largest audit firms worked together, through the Policy and Reputation
Group (PRG), to identify the key factors contributing to audit quality.
 11 metrics were identified and disclosed in the firms’ 2014 Audit Transparency
Reports, measuring activity across a number of important areas.
 We recognise the importance of being able to compare the performance of firms over
time, as well as the extent to which the firms are active in each area, so the firms have
again agreed for the same metrics to be disclosed in this year’s Audit Transparency
Reports, alongside the prior year comparatives.

These metrics are

a. Metrics on external investigations related to audit
b. Metrics on external investigations related to other matters
c. Metrics on audit quality reviews, Metrics on partner and staff tenure
d. Metrics on investment
e. Investment in research and development on assurance in the Audit service line
f. Metrics gathered by staff survey
g. Metrics on investor liaison.

Audit Committee Chair survey

 Audit committee chairs scored their auditors highly across all questions, with a
pleasing improvement in the perception of professional skepticism compared with
previous years.
 Respondents were asked to rank their responses on a scale of 1 (low) to 7 (high).

Managing Risk

PRIORITY RISKS AND MITIGATIONS

Systemic or major failure of audit quality or compliance with audit independence rules

Mitigations
 Response to audit quality observations raised by the FRC’s AQR, the ICAEW’s
QAD team or the PCAOB
 Audit Professional Standards Review
 Processes to capture significant economic and industry risks which have an
impact on audit quality
 Audit Centres of Excellence
 Deloitte and personal independence systems and monitoring. Due to the
changing regulatory requirements, increasing stakeholder expectations and the
importance we attach to independence, we have set out in appendix 1 a detailed
list of our independence systems and processes
 Annual certification of compliance with independence rules by all members of

30 | P a g e
 staff

Mitigations below (as applied to evolving services and delivery models) apply equally to audit
quality.

Failure to manage the quality of evolving services and client delivery models

Mitigations
 Deloitte-wide Quality & Risk community led and staffed by dedicated
experts. Established quality policies, processes and procedures on specific
regulatory, legal, ethical and professional requirements.
 Innovation Investment Board with senior Quality & Risk members
 Modified Quality & Risk processes, systems and training in response to
changing nature of services delivered
 Delivery Model programme
 Delivery Centre risk registers
 Practice and portfolio reviews of engagements and clients

Failure to deliver our desired client portfolio

Mitigations
 Clients & Markets strategy with supporting operational function
 Client portfolios and programme, including audit capture and focus on
multi-disciplinary model
 Governance structure through the Public Policy Group to ensure the firm
develops a strong, coordinated and consistent voice in the market, including
on the impacts of Brexit
 Aligned and agreed KPIs that are monitored

Failure to manage regulatory and public interest threats

Mitigations
 Stakeholder Engagement Programme to communicate our position and what
we stand for and to use these interactions to shape our strategy
 Responding to public policy and regulatory consultations
 Three Independent Non-Executives (INEs) on the Board and PIOC
 A Public Interest Review Group to review potentially contentious public
interest matters
 A Tax Review Panel to consider the reputational issues associated with
complex tax engagements
 Ethics approach (including our Ethics Code and Speak-up Line) to provide
our people with guidance and support

Failure to deliver the culture and talent strategy

Mitigations
31 | P a g e
  Robust HR policies including Equal Opportunities, Respect & Inclusion and
Agile working Deloitte Code, incorporating ethical principles and Deloitte
Global shared values, complemented by an enhanced ethics approach
including whistleblowing and Speak-up Line processes and reporting
channels
 Audit talent model transformation programme
 Transition to the new HR operating model, incorporating business
continuity
 Embedded new performance management approach with supporting
technology

Failure to manage data security and privacy

Mitigations
 A centralised group security function in the form of the Deloitte Business
Security team with defined data security responsibilities
 Defined security strategy including information security policies, processes,
guidelines and ongoing member firm collaboration
 IT technical solutions including, but not limited to, encryption, data leakage
protection, privileged access management, event monitoring and incident
management
 Good practice logical and systems management control
 Implementation of third party risk assessment framework in order to ensure
the firm continues to meet regulatory and client requirements
 Physical security controls covering premises access and working areas
 Personnel security and vetting controls
 Security training and awareness programme
 ISO 27001/Cyber Essentials Plus certification and audit
 Business Resilience and IT Disaster Recovery processes
 General Data Protection Act implementation programme

Failure to ensure the IT infrastructure supports the current and future business models

Mitigations
 IT Strategy objectives and assessment of future technology requirements
 IT framework in line with the IT Service Management Infrastructure Library
(ITIL) and Control Objectives for Information and Related Technology
(COBIT) standards
 An IT Risk Committee comprising key stakeholders from IT, Quality &
Risk and Deloitte Business Security which considers IT infrastructure
matters
 New Service Management team and processes
 Review of known errors caused by interoperability issues
 IT Disaster Recovery capability and process
 Monitoring of service level agreements for third party IT providers

32 | P a g e
 ·
Failure to innovate our core services, and create adjacent or transformational services, and
thus not respond to changing client needs

Mitigations
 An embedded innovation strategy focused on refreshing Deloitte’s core
products and services as well as developing new business offerings
 Creation of global Audit & Assurance platforms to deliver innovation
 An incubation programme to accelerate sustainable businesses that harness
disruptive trends and technologies
 Programme of delivering internal and client deployments focused on
disruption and development of business models
 Focused leadership from a dedicated member of the firm’s Executive
ensuring our response to disruptive change is mandated throughout the firm

Failure to create a resilient operating model and capacity for change within the firm that
aligns to Deloitte Global network strategy

Mitigations
 Strong central governance established with detailed implementation actions
across business functions
 Alignment of Audit operating model to client value
 Chief Operating Officer role on the Executive
 Alignment of Partner objectives to support strategic and operational goals
 Strategic and operational targets embedded within the business
 Strong UK representation and participation in Deloitte Global leadership
and governance bodies

Failure to have clear succession planning for key leadership roles

Mitigations
 Regular review of succession planning and accountability at Executive level
 Ensure a strong pipeline of future senior leaders
 Establish a pipeline of candidates for elected leadership roles in the context
of operating structure

H. Deloitte University
Deloitte’s people are the most important asset, and place a high priority on fostering a
leadership culture focused on the development and well-being of our professionals.

Deloitte University(DU) is Deloitte’s most visible and important investments to continue to

focus on growing the world’s best leaders; allowing ideas to prosper; and making an impact that
matters for the clients, the people, and the communities they serve. It is where learning meets
33 | P a g e
leadership where knowledge, experience, and values are fostered and passed on.

Significance of idea generation and problem-solving at Deloitte and DU

Deloitte generates ideas and solve problems that make a meaningful impact on clients,
people, and society and DU is the physical space where best thought leaders bring together, foster
conversations, build capabilities, and create learnings that can be repeated within and outside the
walls of the organization

Idea generation process at Deloitte

The collaborative learning environment enables professionals to practice problem-solving skills

and gives them more confidence to apply these skills to real-life situations. Finally, also testing
new and innovative strategies such as gamification and the Wicked Problem approach.

II. Navarro Amper and Co.

A. History
Deloitte practices operating in Brunei, Cambodia, Guam, Indonesia, Lao PDR, Malaysia,
Myanmar, Philippines, Singapore, Thailand and Vietnam have joined together to form Deloitte
Southeast Asia. As trade borders dissolve and the world globalises, Deloitte member firms’ clients are
demanding consistent and high quality service across borders. The formation of Deloitte Southeast
Asia is one way this level of service can be delivered in the current environment.
In Philippines, the services are provided by Navarro Amper & Co and other related entities
in Philippines (“Deloitte in Philippines”), which are affiliates of Deloitte Southeast Asia Ltd. It is one
of the leading professional services firms in Philippines. Deloitte Southeast Asia Ltd is a member firm
of Deloitte Touche Tohmatsu Limited.

LMSC
1988
represented Ernst
& Whinnys
Lost the
representation of 1989
E&Y to P&A
LMSC was appointed
1993
as the GTI
correspondent
LMSC was declared 34 | P a g e
as the C&L member 1995
firm
 1997 C.L Manabat &
Co.
Appointed as the
correspondent
firm of GTI

CLMC became a
1999 member firm of DTTL

Joined the DTT

2006
ASEAN Cluster

CLMC was renamed

2007 to Manabat Delgado
& CO.
Renamed to
Navarro Amper & 2012
Co.

Initially set-up as C.L Manabat & Co. in 1997, the firm expanded its services from
management consulting to the full range of audit, tax, risk and financial advisory, and business process
solutions.
In 1999, the firm joined the Deloitte global network. The Deloitte global affiliation combined
with the firm’s growing reputation in the local market led to double digit growth in clientele and
resources. We employ about 450 professionals in 2 cities - Bonifacio Global City (BGC) in Taguig
and Cebu - offering an array of professional services, serving a wide range of clients across various
industries.
As of fiscal year 2017, the key executive of the firm are Mr. Greg S. Navarro as Chief
Executive Officer and Managing Partner, Mr. Bonifacio F. Lumacang as Audit Assurance Leader, Mr.
Fredieric B. Landicho as Tax & Corporate Services Leader, Mr. Luisito T. Amper as Enterprise Risk
Services Leader, and Mrs. Imelda Tapay-Lapres as Financial Advisory Services and Business Process
Outsourcing Leader. Currently, the managing partner & CEO is Mr. Fredieric B. Landicho.
The firm caters different kinds of client, which includes major multinationals, large national
enterprises, public institutions, local important clients and successful fast growing global companies.
Its clients come from major industries such as banking & finance, manufacturing, transportation,
technology, media, telecommunications, retail & wholesale, oil & gas, mining, and life sciences &
healthcare. Some of them are Century Pacific Food, Inc., Holcim Philippines, Inc., and Globe
Telecom, Inc.

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Organizational Structure

B. Services and Industry

Deloitte offers multidimensional approach addressing to each of their client’s issues.

The firm is using their combined audit & assurance, risk advisory, tax, financial advisory and
consulting knowledge to understand and evaluate client issues in a ‘big picture’ context. This
360° perspective is what they call the Deloitte difference. By applying this approach, they
provide greater value to the clients they serve.

Services

 Audit and Assurance Services. Quality and Integrity

Audit and assurance services of Deloitte sits at the very heart of their multidisciplinary
offering to clients. It is grounded on a precise understanding of each client and the
industry and environment in which they operate. Due to their excellent reputation, Deloitte
gives peace-of-mind audit services which provides great potential for competitive success
and growth.

Deloitte is developing a new generation state-of-the-art audit tools. It enables member

firms to continue delivering the quality assurance services that is inherent in the Deloitte
brand and which the public and financial community expect. Professionals are supported
by advanced technology, including the audit proprietary AS2 (Audit System 2) and
Engagement Management System (EMS) as an audit tool. Audit process is integrated
with these technology, we are able to make audit decisions by conducting robust
diagnostic tests and analytical reviews.

• Audit
 Due diligence
 Financial audit

• Assurance

 International and local financial reporting standards

 US GAAP
 IFRS
 Public listing

36 | P a g e
  Revenue recognition
 Securitization

Our Global IFRS and Offerings Services (GIOS) professionals provide a diverse range of
services ranging from IFRS implementation services, reporting advisory services and cross-
border offerings services.

 Risk Advisory Services. Insightful and integrated

Deloitte is building risk solutions that incorporate dashboard systems and is

supporting the standardization of terms, metrics, reporting, and operational charters
across risk management silos. It sees the need to educate the board of directors as
critical to evolving risk solutions and is using tools such as the Risk Map to facilitate
that process

The Risk Intelligence Program Methodology applies to nine fundamental principles

for building a risk intelligent enterprise. It is a holistic and unifying approach for
building an effective and efficient risk management program. It is also scalable to
transform an organisation’s risk management capabilities.

Following the nine fundamental principles of risk intelligence, the risk advisory
professionals help organisations develop and integrate effective risk management
practices across all organisational levels:

• Risk governance, including strategic decision-making and risk oversight, led by

the board of directors

• Risk infrastructure and management, including designing, implementing, and

maintaining an effective risk program, led by executive management

• Risk ownership, including identifying, measuring, monitoring, and reporting on

37 | P a g e
 specific risks, led by the business units and functions

Our enterprise risk services include

• Business continuity and crisis management services

• Business process improvement and internal audit services
• Data analytics
• Enterprise risk management services
• Information risk management services
• IT governance services
• Risk management technology implementation services
• Security, privacy and resilience services

 Tax. Effective and Efficient

Practical and well-crafted tax solutions are critical parts of an effective business
strategy and at Deloitte, its tax professionals keep companies abreast of developments
that affect your business and help interpret their significance. Deloitte professionals
collaborate to identify and implement tax strategies that work best for clients and
optimise group tax benefit always ensuring that you are fully compliant with all
applicable tax laws.

For clients who are planning to venture abroad, Deloitte’s tax professionals can
provide advice in structuring investments and business transactions to minimise the
overall tax liabilities. They also help in structuring compensation arrangements to
minimise personal income and social security taxes as well as providing
comprehensive tax planning for expatriate assignments. In this way, the company
ensures that as a group, your organisation minimises its worldwide tax costs.

In addition, its integrated service offerings which cut across our various functions and
multiple tax service lines, present unique value propositions to clients. For example,
tax aligned supply chain planning and implementation services bring together
management consulting professionals and tax professionals across multiple tax service
lines such as international tax, transfer pricing and indirect tax, to design tax efficient
and streamlined supply chain solutions for clients.

Our tax services include:

• Corporate tax compliance and planning

• International tax planning
• Mergers and acquisitions – tax due diligence and structuring
• Transfer pricing – planning, documentation, audit defence and unilateral and
bilateral APAs
• Indirect tax – GST/VAT and customs duty compliance and planning
• Global employer services – tax efficient compensation planning and compliance
• Tax audit and investigation

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 Deloitte’s specialists, many of whom are recognised for their eminence, will advise
companies on addressing challenges, and identifying and capitalising on opportunities,
to ensure that your global effective tax rate is minimised and that they are fully
compliant with all applicable tax laws in all the countries in which you operate.

 Financial advisory. Strategic and innovative

Financial advisory services professionals provide a diverse range of strategic and

financial advice to clients throughout the region in relation to merger and acquisition
(M&A) services (including corporate finance, M&A transaction services and valuation
services), restructuring and forensic and dispute services.

Deloitte delivers tailored solutions to the complex challenges that business leaders face
when undertaking corporate transactions. Senior-level attention throughout delivers
objective, expert advice to help business leaders make better decisions on deals. The
solutions that Deloitte delivers span the deal cycle – from the development of strategy,
to identifying and selecting targets for acquisition, preparing a business for sale,
structuring and pricing the deal, advising throughout negotiations, managing
completion processes or preparing for the challenges of integration.

Forensic & Dispute Services team understands these issues on a local level and in a
global context. They have worked with many of the world’s largest firms to help them
mitigate risk and manage unforeseen events.

Our financial advisory services include:

• Corporate finance
• Due diligence
• Valuations
• Financial restructuring
• Dispute consulting and forensic services
• IPO and capital markets services
• Litigation support
• Reorganisation services

Deloitte’s strength lies in its ability to offer independent, objective advice to clients
around the region. Its independence from debt and equity providers allows the
company to avoid the conflicts of interest inherent in some financial institutions.

 Consulting. Multidimensional and collaborative

Deloitte offers a wide range of consulting services, and work closely to deliver
sustained improvements in business performance, drive shareholder value and create
competitive advantage. With extensive content and deep pool of intellectual capital,
professionals help you identify strategic opportunities and suggest practical, cost-
effective steps to stay ahead of the competition.

Our consulting services comprise:

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 • Strategy and operations
• Human capital
• Technology integration
• Enterprise applications
• Outsourcing

With truly integrated professional services organisation, capable of offering solutions

in consulting as well as in tax consulting, risk consulting and financial advisory. Our
consulting capability allows benefit from our full service – from strategic input right
through to technology integration and outsourcing.

The company’s deep pool of talent across many disciplines and industries enables it to
genuinely deliver a comprehensive solution to clients – whatever their size,
geographic profile or need.

With access to skills and talent across the globe, unrivalled team architecture means
can meet any client’s demand for single-source solutions.

Industry

 Consumer and Industrial Products

 Energy & Resources
 Financial Services
 Life sciences & Healthcare
 Public Sector
 Technology, Media & Telecommunications
Its deep industry expertise means they are able to focus on the specific needs and
challenges of client business, to help gain competitive advantage.

Deloitte do not achieve results; clients do. Its objective is to help them do so as
effectively as possible.

C. Employee as an Asset

Benefits
 Insurance, Health & Wellness
Health Care Insurance

 Financial and Retirement

Performance Bonus

 Family and Parenting

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 Unpaid Extended Leave
Maternity and Paternity Leave
 Vacation and Time Off
Vacation and Paid Time Off
Bereavement Leave
Sick Leave

 Perks and Benefits

Employee Assistance Program

 Professional Support
Apprenticeship Program
Job Training and Tuition

Learning Programs

As highly regulated professionals, continuous learning programs are offered to

professionals based on the requirements of the regulatory bodies and internal learning
curriculum compliant to global standards.

 Technical
Standards-based: IFRS, USGAAP and ISA
 Policies and regulatory rules
Laws, regulatory and global requirements
 Skills
Personal development and soft skill enhancement

Salary

POSITION COMPENSATION (Approx)

Junior In Audit 17000-19000 monthly
Audit Associate 18000-19000 monthly
Auditor 15000-21000 monthly
Audit Senior 24160 approx monthly
Assistant Manager 45000-49000 monthly
Consultant 86000-93000 monthly
Senior Manager 126000-136000 monthly
Director 1.44M-1.57 M yearly

D. PRACTICES ON ETHICS

Deloitte SEA commits to the Global Principles of Business Conduct (“Global Code”).

41 | P a g e
The Global Code is based on our Shared Values and reflects the core belief that, at Deloitte,
ethics and integrity are fundamental and not negotiable. Deloitte SEA’s Code of Ethics and
Professional Conduct ("SEA Code") encompasses the Global Code, and builds on it, as
appropriate, addressing local requirements.
The SEA code is also developed based on the requirements in the Code saof Ethics for
Professional Accountants issued by the International Ethics Standards Board (IESBA). The
SEA Code describes member firm’s ethics program, including key contacts and channels for
consultation on issues and reporting suspected misconduct. The Global Code and the SEA
Code and ethics program define the Deloitte approach to building and sustaining a culture of
ethics and integrity.
The company also have a responsibility to raise their voice when they become aware
of anything that is inconsistent with it. There can be serious consequences for noncompliance
with the SEA Code, or related Deloitte policies, up to and including dismissal.
Consultation goes to the heart of the Deloitte culture, and avoids people having to
resolve a difficult ethical situation alone. Individuals are encouraged to consult with their
colleagues, line managers, leaders or their member firm’s normal reporting channels. In
addition, formal ethics reporting channels are available for those who seek a confidential
route for consultation.
At Deloitte, they take reports of misconduct seriously, conducting investigations
where necessary, and addressing issues appropriately. Retaliation against those who raise
ethical concerns in good faith is not tolerated
With strong firm leadership support, the SEA Code and the firm’s ethics programs
define the Deloitte approach to building and sustaining a culture of ethics and integrity.

A. We commit to serving clients with distinction

Integrity
At every level, the people of Deloitte SEA are expected to be honest, trustworthy, candid,
and straightforward in both personal and business dealings, in accordance with both the
letter and the spirit of all applicable laws and regulations.

Honesty and Trust

Deloitte SEA is commited to fostering and maintaining a culture of trust. Honesty in the
dealings with each other is essential. Each person is individually responsible for both the
quality and the on-time completion of our work.

Quality
This quality expectation is very simply stated — in the perceptions of both the public and its
clients, the services provided by the firm should meet all applicable professional standards.

Independence and objectivity of professional advice and conclusions

In working with the firm's clients, Deloitte's policy is to be forthright, direct and
independent in conveying advice or rendering an opinion. The personnel should not allow
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prejudice, bias, conflict of interest, or undue influence of others to override their objective
professional or business judgments.

Records accuracy
Personnel who enter information into the firm’s business records have a responsibility to do
so in a truthful, accurate, legible, complete and timely manner and in accordance with the
firm’s policies and all legal and professional standards and regulations.

Records Management
To help preserve the integrity of the record-keeping and reporting systems, all personnel
have an obligation to know and comply with all current applicable records retention policy
and procedures. Personnels never destroy, alter or cause the destruction or alteration of
documents for any illegal or improper purpose.

Independence from clients

The people of Deloitte SEA are pledged to maintaining independence, both in fact and
appearance, from clients in exercising appropriate professional responsibilities. All
applicable personnel must be financially independent of Deloitte SEA attest clients, and
maintain an independent and objective attitude in performing services for all clients.

Billing for professional services

Every firm is committed to properly recording hours worked and expenses incurred in its
time and expense reporting systems, in accordance with its applicable policies, and allocate
such charges to the appropriate project or client service charge codes.
Communications systems
Our communication systems, including — among other things — computers, electronic
mail, intranet and Internet access, instant messaging, telephones, voice mail, conferencing
systems, and paper documents are the property of Deloitte SEA and are to be used primarily
for business purposes. All personnel have a responsibility to maintain and enhance our
public image and to use all communication systems in a productive manner.

Conflicts of interest
In making decisions, the firms are responsible for remaining free from the influence, or the
appearance of influence, of any conflicting interests, and for conducting business ethically
and legally. They have a duty to avoid making business decisions that place personal
interests ahead of those of Deloitte SEA.

Professional competence and due care

Deloitte firms continually strive to improve the quality of services to clients and exercise
due care in the management of client engagements by matching client needs with personnel
who have the appropriate technical training and the competence required for their
assignments.

Scope of services
Deloitte SEA will not overstate its ability to deliver services, nor will it offer or provide any
services that will damage its reputation or the reputations of clients.

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 Respect for competition
Deloitte SEA honours the non-compete agreements (sometimes known as restrictive
covenants) of competitors. The non-compete agreements applicable to Deloitte SEA’s
existing and former personnel are also strictly enforced.

Confidential and proprietary information

Confidential or proprietary information about the clients, the organisation, or other parties,
which has been gained through employment with Deloitte SEA, shall not be used for
personal advantage or for the benefit of third parties.

Privacy and data protection

The firms shall not disclose people’s personal information to any Deloitte SEA / DTTL
personnel unless this is necessary for them to perform specific and authorised tasks, or to
any person or entity outside Deloitte SEA/DTTL unless expressly authorised to do so.

External enquiries
The firms should always exercise care not to disclose confidential, personal or business
information through public or casual discussions with the media, government officials, or
other parties.

Insider trading
It is illegal for any personnel employed by the firm to buy or sell any securities (i.e., shares,
bonds) based on insider information, or to discuss such information with others who might
buy or sell such securities.

B. We commit to inspiring our talented professionals to deliver outstanding value

Diversity and inclusion
Deloitte SEA is committed to fostering a diverse and inclusive culture. Such a culture
directly supports its mission to help its people and our clients excel.

Respect and fair treatment

All personnel are expected to treat their colleagues with respect. Unlawful discrimination,
verbal or physical harassment or abuse, or offensive behaviour (whether or not sexually
related) by personnel, agents, or clients of Deloitte SEA will not be tolerated.

Personal relationships
Personal relationships, romantic or otherwise, between two people employed by Deloitte
SEA or with an employee of a client organisation (attest or non-attest clients) must be
reported by the persons involved to the appropriate office, service line leader or practice
entity head who will then consult with the Human Resources department to determine what,
if any, notifications or assignment changes need to be made.

Licensing and professional certifications

All personnel holding professional licenses and certifications have a personal responsibility
to maintain such licenses and certifications in good standing through timely renewals, and

44 | P a g e
 (where required), the attainment of the appropriate level of continuing professional
education.

Consultation
As a minimum, consultation on non-routine or emerging issues or practices is not only
expected, it is required.As professionals, all personnel have a duty and an obligation to
express differing points of view and appropriately resolve such matters in an open-minded
and professional manner.

Health, safety and the environment

Transactions pertaining to illegal drugs or other controlled substances by a partner,
executive director, principal, director or employee is prohibited and is cause for termination
or suspension. Also, all appropriate liquor laws must be followed. Moreover, threatening,
aggressive, or abusive behaviour towards fellow colleagues or others in the workplace will
not be tolerated. Explosives, firearms, or other weapons, whether legally permitted or not,
are not allowed in any of the facilities of Deloitte SEA.

Whistle blowing
It is necessary to report any signs of negligence, abuses or dangers that might result in
serious personal, commercial or social damage. If superiors do not act to curtail or mitigate
such negligence, abuses or dangers, it may be necessary to ‘blow the whistle’ to help correct
the problems or reduce the risk.

C. We commit to contributing to society as a role model for positive change

Anti-corruption
Deloitte SEA is against corruption in any form and stand firmly against bribery in order to
contribute to good governance, economic development, and the improvement of social
welfare wherever it does business.

Money laundering
It is the obligation of everyone in Deloitte SEA not to commit money laundering offences.
Deloitte SEA is committed to complying with all applicable laws and regulations
concerning anti-money laundering efforts.

Government transactions and relations

All personnel involved in providing services to governmental entities are required to adhere
to the government’s ethical standards as they apply to the services of the firm, as well as the
SEA Code.

International business
Deloitte SEA expects its personnel conducting international business to know, understand,
and abide by the relevant laws of the countries in which they do business.

Gifts and entertainment

Personnel of Deloitte SEA should not offer or accept gifts or payments, or undertake
inappropriate activities, to facilitate any engagement. Entertainment of its personnel or
45 | P a g e
 clients that is lavish or inappropriate in nature is also not permitted.

Supplier, contractor and alliance partner relationships

Procurement decisions should be based on objective business rationale and not on personal
interest or bias.

Responsibility to society and community involvement

Deloitte SEA has a responsibility to be a good neighbour and a contributing corporate
citizen in the communities in which its people work. Deloitte SEA is committed to
conducting our business activities in ways that honour ethical values and respect people,
communities, and the natural environment.

Truth in communications
It is Deloitte SEA's policy to communicate facts about its capabilities, policies, and people
accurately and responsibly in advertisements, sales, marketing, recruiting and all other
promotional materials.

Social Media
All personnel, when dealing with social media, are expected to be true to themselves,
respect their audience, tend the community garden, add value, and consider the future.

E. Practices in Team Engagements

 Deloitte Southeast Asia Code of Ethics and Professional Conduct (SEA Code)
The role of the SEA Code
Deloitte considers the need for specifically-tailored ethical and professional
protocols to address differences in legal requirements and client expectations in its
member firms. Deloitte's SEA Code of Ethics and Professional Conduct is the standard
adopted by the organization’s network firms in Southeast Asia including the Philippines.
The SEA Code encompasses the Global Code, and builds on it, as appropriate,
addressing local requirements. The SEA code is also developed based on the requirements
in the Code of Ethics for Professional Accountants issued by the International Ethics
Standards Board (IESBA). The SEA Code describes its member firm’s ethics program,
including key contacts and channels for consultation on issues and reporting suspected
misconduct.
In addition to the Global Code which is fully integrated in the SEA Code, it also
lays out specific guidelines on how every partner and staff at Deloitte would conduct its
measures whenever faced with an ethical dilemma.

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  Ethical decision-making framework

Step 1: Identify dilemma

Step 2: Consider alternatives
Step 3: Consult with experts
Step 4: Decide and implement

Step 1: When faced with a situation, identify the dilemma and assess its potential risk to the
firm, your colleagues, others and yourself. In assessing potential risks, you may ask yourself
the following questions that may help you determine the appropriate plausible alternative
actions

• Are my actions illegal, unethical or not in compliance with the standards of our profession?
• Am I compromising my integrity or the integrity of the firm or the integrity of our clients?
• Am I being fair and honest?
• Am I personally uncomfortable about the course of action?
• Could the intended action appear inappropriate to a third party?
• Am I treating others the way I expect others to treat me?
• Could someone’s life or reputation be endangered by my action?
• Would I be unwilling or embarrassed to tell my family, friends, or colleagues?
• Would my reputation or the reputation of the firm be harmed if the action was publicly known or
reported such as in newspapers or other broadcast medium?

Step 2: Consider the alternative actions and the potential outcomes and consequences of each
action. You might consider:

 What are the facts; what additional data/information would be helpful?

• What section(s) of the SEA Code may be applicable in this situation?
• What policies and/or laws may apply?
• Who should be consulted?

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Step 3:If you are unsure about your alternatives, you should consult with subject matter experts or
leaders in the firm. You might consider:

• Which key leaders in your function should be made aware of the situation?
• Which subject matter expert(s) would be in a position to provide valuable insight into this situation?
Does the situation warrant discussions with Risk Management, Ethics, Human Resource, Legal Counsel,
or other senior leadership in the firm?

Step 4: Decide on the best course of action and implement it.

Investigations and disciplinary actions

The SEA Code grants its member firms the prerogative to impose corrective action and/ or
disciplinary sanctions to address any violation. Examples of actions that may be taken for violations of a
law, professional standards or regulation, policy, the SEA Code, the
Shared Values or Global Code include, but are not limited to:

• Written reprimand;
• Retraining or counseling;
• Reassignment or suspension from work with or without pay;
• Removal from managerial position;
• Monetary fines or reduction in partnership units or earnings group level;
• Termination or suspension from duties; and/or
• Prosecution.

Report Ethical Violations and Noncompliance Issues

The SEA Code further stresses out guidelines to the organization's partners and staff on where and
how to report ethical violations and noncompliance issues, both known and potential, in the conduct of their
services.

Assistance with ethics and compliance matters

Deloitte practitioners may report known and potential breach of ethical conduct and compliance
protocols to their supervisor or service line leader or practice entity head. If they are unable to resolve the
issue (or if they are uncomfortable discussing the issue with them), they should seek assistance from other
parties, such as:

• the Ethics Office of Deloitte SEA or the Ethics Officers in any of the SEA practices;
• Human Resources Department; or
• the Ethics Helpline.

All our reporting methods ensure that a reporter’s identity is not revealed and each report is treated
with the highest degree of confidentiality. Every reasonable effort will be made to keep the identity of the
person reporting a violation, confidential, to the extent possible, consistent with good business practice. In
order to assist in the investigation, those reporting potential violations are encouraged to identify

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themselves. However, anonymous reports will also be accepted and investigated to the extent possible.

When making a report to the Ethics Office of Deloitte SEA:

• You are requested to provide the most detailed information possible about the incident you are
reporting — who, what, why, where, when and how.

• You are asked to identify yourself. Every reasonable effort will be made to keep your identity
confidential. You may choose to remain anonymous; however, doing so may prevent us from fully
investigating the matter. Therefore, you will be encouraged to identify yourself whenever possible.

• The Ethics and Compliance Office will accept and acknowledge all reports that are not anonymous
within two business days and then determine the appropriate next steps.

• Web-based submissions are not tracked. No web or email identifiers will ever be used. You may
send a mail to the web-based Ethics Helpline or you can also submit anonymous reports by email.

• Reprisals or retaliation against any person because he or she, in good faith, reported an ethics or
compliance concern will not be tolerated.

• Disciplinary action is based on substantiated findings, not simply on the contents of a report.

Threats

 Engagement Familiarity
 The common safeguard for this threat is the regular rotation of clients across partners.
 Investment holdings to Firm’s clients and directorship to organizations
 Monthly independence check across all professionals and regular monitoring of
changes in holdings.
 Ethical breach in the conduct of audit procedures
 Engagement review within the team and independent review by QA and Technical
Group.
 Ethics hotline directed to Ethics Leader.

G. Independence
The International Standards on Auditing promulgated by IFAC through IAASB sets out
guidelines in the overall conduct of audit.
This is in addition to local statutory requirements on independence. The Firm has a
dedicated support group that handles concerns relating to independence, reputation and risk and
ethics.
This is comprised of partners and support staff that ensure that the professionals and
engagements comply with guidelines and policies established by the Firm and Global Network.
This begins prior to engagement acceptance, where necessary background and independence
check is being performed, as well as staff assignment to ensure that any threat to independence is
mitigated. Monthly monitoring of independence is also in place to ensure that regular checks on
changes in professionals’ holdings, if any, are documented.
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H. Safeguards

 Physical Safeguards: Leading Practices

 Always lock your screen
 Always secure your laptop
 Never leave you laptop or mobile device in a car
 Take quick inventory before leaving

 Technical Safeguard: Leading Practices

 Avoid using publicly accessible network
 Ensure your laptop backup is up to date and working
 Do not use DropBox, One drive
 Avoid using unapproved messaging applications for business purpose
 Comply with Deloitte’s strong password policy
 Do not disable encryption
 Use approved encryption tools.

 Quality Service Safeguard

 Existence of QA and Technical group to ensure that all procedures performed in
the engagement are reviewed by an independent team.
 Regular yearly review is being performed to engagements that meet certain criteria
(size and risk-level) are being subjected to review by fellow professional across
SEA.
This review encompasses the entire engagement files, including administrative and
support matters, from client acceptance and retention to archiving of audit files.

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C. APPENDIX

 Global Principles of Business Conduct (Global Code)

We commit to serving clients with distinction.
Integrity
• We are straightforward and honest in our professional opinions and business relationships.
• We are truthful about the services we provide, the knowledge we possess, and the experience
we have gained.

Quality
• We are committed to providing quality services by bringing together the breadth and depth of
our resources, experience and insights to help clients address their needs and problems.
• We strive to develop outcomes that create an impact that matters for our clients.

Professional behaviour
• We comply with applicable professional standards, laws and regulations and seek to avoid
actions that may discredit ourselves or our professions.
• We foster a culture of appropriate professional scepticism and personal accountability, which
supports clients and drives quality in the services we provide.
• We understand the broader impact that our work has on society, our people, and our clients,
and we conduct business with those interests in mind.
• We are committed to earning and sustaining the public’s trust and confidence in the work we
do.

Objectivity
• We are objective in forming our professional opinions and the advice we give.
• We do not allow bias, conflict of interest, or inappropriate influence of others to override our
professional judgments and responsibilities.
• We do not offer, accept or solicit any gifts, entertainment or hospitality that we have reason to
believe may be intended to improperly influence business decisions or impair objectivity.

Competence
• We use due care to match client needs with practitioners who have the competence required
for their assignments.
• We foster innovation and new ideas to improve the value and performance of our services.

Fair business practices

• We respect our competitors and are committed to fairbusiness practices.
• We receive fees that reflect the value of services provided and responsibilities assumed

Confidentiality, privacy and data protection

• We protect and take measures to safeguard the confidential and personal information that we
hold, collecting and handling it in compliance with applicable laws, professional obligations,
and our own data management policies and practices.

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• We prohibit disclosure of confidential and personal information entrusted to us unless granted
permission or there is a legal or professional right or duty to disclose.
• We prohibit the use of confidential information about our clients for personal advantage or for
the benefit of third parties.

We commit to inspiring our talented professionals to deliver outstanding value.

Respect, diversity and fair treatment

• We foster a culture and working environment where our people treat each other with respect,
courtesy and fairness, promoting equal opportunity for all.
• We encourage and value a diverse mix of people, viewpoints, talents, and experiences.
• We create inclusive working environments that not only address individual needs, but allow
our people to utilize their unique strengths.
• We do not tolerate harassment or unfair discrimination in our working environments

Professional development and support

• We invest in our people to develop the professional knowledge and skills necessary for them
to effectively perform their roles.
• We help our people reach their potential through investments in personal and professional
development and support programs.
• We provide a safe work environment for our people and expect our clients to do the same.

We commit to contributing to society as a role model for positive change.

Anti-corruption
• We are against corruption and neither make bribes nor accept them, nor induce or permit any
other party to make or receive bribes on our behalf.
• We support efforts to eradicate corruption and financial crime.

Responsible supply chain

• We do not condone illegal or unethical behaviour by our suppliers, contractors and alliance
partners.
• We select suppliers through fair procurement processes.

Social responsibility
• We contribute to society and communities by engaging with non-profit organizations,
governments, and other businesses to make a positive impact on local, national or global
challenges.
• We support our communities in a variety of ways, such as donating money, providing pro
bono client services and supporting the volunteering of time by our people.
• We support efforts to drive sustainable development and we respect human rights standards.
• We recognize that our business operations and our provision of services may at times impact
the environment and we work to reduce harmful effects they might have.

 Code of Ethics and Professional Conduct ( SEA Code)

The Clients. We commit to serving clients with distinction.

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PROFESSIONAL STANDARDS

Integrity

Integrity means always trying to do the right thing, the first time, every time. At every level, the
people of Deloitte SEA are expected to be honest, trustworthy, candid, and straightforward in both
personal and business dealings, in accordance with both the letter and the spirit of all applicable
laws and regulations. All personnel are encouraged to exceed the expectations of clients — and
each other — by seeking to do not only what is legal, but also what is right. Our commercial
ambitions should never be allowed to overtake professional and ethical responsibilities.

Honesty and trust

We believe that our people work best in a culture of trust, and we are committed to fostering and
maintaining such a culture. We expect our colleagues to perform their jobs with integrity and to
conduct themselves ethically at all times. Honesty in the dealings with each other is essential. We
are each individually responsible for both the quality and the on-time completion of our work. We
must also accurately and honestly account to each other for time worked and expenses incurred (in
accordance with Deloitte SEA policy) for both internal and client-related activities.

Quality

Our reputation is wholly dependent not only on the integrity of our people, but also on the quality
of the services provided. This quality expectation is very simply stated — in the perceptions of
both the public and our clients, the services provided by the firm should meet all applicable
professional standards. Each person is individually responsible for the quality of the professional
services we provide. Commitment to quality operates at three levels: the individual, the team, and
the organization. At every level, it requires dedication, having pride in your work produced and an
appropriate sense of professional skepticism in the conduct of our work.

Independence and objectivity of professional advice and conclusions

In working with our clients, our policy is to be forthright, direct and independent in conveying
advice or rendering an opinion. We do not allow prejudice, bias, conflict of interest, or undue
influence of others to override our objective professional or business judgments. In return, clients
are expected to meet the letter and the spirit of all applicable laws and regulations. There is no
client or engagement that is more important than our responsibility to sustain public trust, our
commitment to do the right thing, and to maintain our good reputation. We will always support our
personnel who stand up to a client they reasonably believe may be engaging in illegal or
inappropriate financial reporting or other business activities.

Records accuracy

Accurate and complete records are required for compliance with regulatory, tax, and financial
reporting requirements, among other things, as well as for meeting our obligations to clients.
Personnel who enter information into the firm’s business records (including, but not limited to,
time, expense, and client billing records, regulatory or other financial reports) have a responsibility
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 to do so in a truthful, accurate, legible, complete and timely manner and in accordance with the
firm’s policies and all legal and professional standards and regulations.

Records management

We will maintain all records in accordance with the legal and business requirements appropriate to
our profession. To help preserve the integrity of the record-keeping and reporting systems, all
personnel have an obligation to know and comply with all current applicable records retention
policy and procedures. These include how data is shared, stored, and retrieved, and the
circumstances under which it may be disposed of.

Changes to and destruction of records are specifically forbidden in the following circumstances:

• Where prohibited by law, by government regulation, or by policy of Deloitte SEA;

• Where there exists an overriding governmental, regulatory or contractual requirement; or

• Where there is knowledge of — or anticipation of — a court order or other request for

documents, a regulatory investigation, or a lawsuit.

We never destroy, alter or cause the destruction or alteration of documents for any illegal or
improper purpose. Records include — among other things — paper copies, electronic files, and
video and audio recordings.

Independence from clients

Deloitte SEA and its personnel are committed to complying with all laws and regulations dealing
with professional independence requirements.

The people of Deloitte SEA are pledged to maintaining independence, both in fact and appearance,
from clients in exercising appropriate professional responsibilities. All applicable personnel must
be financially independent of Deloitte SEA attest clients, and maintain an independent and
objective attitude in performing services for all clients.

Deloitte SEA will not render any service or enter into any supplier agreement that would impair
independence with regard to attest clients. Deloitte SEA monitors its services and relationships to
ensure these goals are achieved.

Billing for professional services

We are committed to properly recording hours worked and expenses incurred in our time and
expense reporting systems, in accordance with our applicable policies, and allocate such charges to
the appropriate project or client service charge codes. We have an obligation to accurately bill
clients for fees and expenses, in accordance with the terms of our engagements.

Communications systems

Our communication systems, including — among other things — computers, electronic mail,
intranet and Internet access, instant messaging, telephones, voice mail, conferencing systems, and

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 paper documents are the property of Deloitte SEA and are to be used primarily for business
purposes.

All personnel are encouraged to use the Internet and email in order to make communications more
effective and efficient. However, the main purpose of these communication systems is to facilitate
business. All personnel have a responsibility to maintain and enhance our public image and to use
all communication systems in a productive manner. The integrity of these communication systems
also requires that all personnel secure their personal access information in order to prevent
unauthorized access to such systems.

Our communication systems may be used for incidental and occasional personal use provided that
such use is kept at a minimum and is in compliance with the SEA Code and applicable policies
and procedures. However, because such systems are owned by Deloitte SEA, all users
automatically waive any claims to privacy. Furthermore, Deloitte SEA reserves the right to
monitor all communications (e.g., email, voicemail, computers, and documents).

The Deloitte SEA Information Technology Acceptable Use Policy outlines in detail the
appropriate use of technology-related equipment and should be consulted for additional details.

Conflicts of interest

In making such decisions, we are responsible for remaining free from the influence, or the
appearance of influence, of any conflicting interests, and for conducting business ethically and legally. We
have a duty to avoid making business decisions that place personal interests ahead of those of Deloitte
SEA.

Some examples of potential conflict situations include:

• Acting as a director, partner, consultant, or employee of an organization that provides

services, supplies, or equipment to, or is a competitor of Deloitte SEA;

• Holding a second job that may interfere with your employment at or being a partner,
executive director, principal, director or employee of Deloitte SEA;

• Ownership by you or members of your immediate family of a financial interest (i.e.,

publicly traded shares) in a company that is a competitor of, supplier to, or client of
Deloitte SEA; and

• Making hiring decisions that involve close relatives of partners, executive directors,
principals and directors of Deloitte SEA.

Professional competence and due care

We observe our profession’s standards of performance in providing professional services. In

addition, we continually strive to improve the quality of services to clients and exercise due care in
the management of client engagements by matching client needs with personnel who have the
appropriate technical training and the competence required for their assignments. Engagements are
planned and supervised using both client’s and firm’s resources and — where appropriate — in

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 consultation with national resources regarding technical or industry-specific questions. We issue
reports that are in accordance with all applicable professional standards.

Scope of services

As an organization that offers quality professional services, we naturally want to be competitive

and successful. Nevertheless, Deloitte SEA will not overstate its ability to deliver services, nor
will it offer or provide any services that will damage its reputation or the reputations of clients.
Our skills, experience, and desire to do the work shall be fairly represented in proposals to clients.
We also make it a point to stand behind service commitments made to clients. Services are
delivered in a professional manner according to Deloitte SEA’s policy as well as the professional
standards and regulations applicable to our profession. We offer only those professional services
that we are competent to perform and supervise, and only those services that will not detract from
the public trust in our independence, integrity and objectivity.

Respect for competition

We will not pursue any competitive tactic or goal that we believe might damage our reputation or
is inconsistent with our vision to be recognised as the best in professional services. We do not
condone any attempts to gather competitive information in a deceptive, unlawful or inappropriate
manner. We honour the noncompete agreements (sometimes known as restrictive covenants) of
competitors. The non-compete agreements applicable to Deloitte SEA’s existing and former
personnel are also strictly enforced. Furthermore, given that our reputation is affected by the
reputations of our competitors, Deloitte SEA does not condone any competitive action that could
be harmful to our competitors.

Confidential and proprietary information

Our personnel have access to significant amounts of client information that may not be available to
the public. Accordingly, you are required to preserve the confidentiality of information obtained in
client service. Information of a private and sensitive nature must be used responsibly, controlled,
and protected to prevent arbitrary and careless disclosures. The disclosure of confidential client
information is prohibited to:

• Anyone who works outside the client’s organisation;

• Anyone within the client organisation without a need to know; or

• Anyone within Deloitte SEA or other DTTL Member Firms, unless there is a legal or
professional right or duty to disclose, or a written client consent has been obtained.

Confidential or proprietary information about our clients, our organisation, or other parties, which
has been gained through employment with Deloitte SEA, shall not be used for personal advantage
or for the benefit of third parties.

Privacy and data protection

We are committed to complying with applicable laws and regulations governing privacy and data
protection. We shall only collect personal information that is necessary for legitimate business or
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 legal purposes. In handling any personal information, we shall process this data fairly and
lawfully; keep it accurate and up-to-date; use it only for its intended, legitimate purposes; keep it
secure and confidential; and retain it for a limited time only, consistent with applicable laws.

We shall not disclose people’s personal information to any Deloitte SEA / DTTL personnel unless
this is necessary for them to perform specific and authorised tasks. We shall not disclose people’s
personal information to any person or entity outside Deloitte SEA/ DTTL unless expressly
authorised to do so.

External enquiries

We should always exercise care not to disclose confidential, personal or business information
through public or casual discussions with the media, government officials, or other parties.
External enquiries (e.g., media and regulators) must be referred to the appropriate Deloitte SEA
resource (Ethics and Reputation and Risk Management or Clients & Markets) for a response. This
includes newspapers, magazines, trade publications, radio, television, and government enquiries,
as well as any other external parties seeking information about Deloitte SEA or its clients. While it
is standard policy to respond to external enquiries in an honest, candid and appropriate manner,
responses may be limited by confidentiality requirements and other related concerns. When public
comments are requested on proposed regulations or professional standards, it is the practice of
Deloitte SEA to provide informed feedback and perspective based on what is believed to be in the
long-term best interest of the capital markets and the profession. Communication with regulators
and standard-setters is conducted through Deloitte SEA using publicly sanctioned means.
Inappropriate or unethical efforts to influence regulation or professional oversight are not
condoned.

Insider trading

Our people may, in the course of performing their duties, come into possession of “material
nonpublic information” about our clients and the companies with whom they do business.“
Material nonpublic information” is any information that would affect the prices of securities, either
positively or negatively, that is not generally available to the investing public. This information is
generally referred to as “insider information”. Buying or selling securities using “insider
information” is referred to as “insider trading”. It is illegal for any personnel employed by the firm
to buy or sell any securities (i.e., shares, bonds) based on insider information, or to discuss such
information with others who might buy or sell such securities.

The Employees. We commit to inspiring our talented professionals to deliver outstanding value
Diversity and inclusion

We are committed to fostering a diverse and inclusive culture. The rich mix of individuals,
viewpoints, talents, and experiences found at the firm is respected and valued. Our human
resources policies aim for the highest standards of fairness and equal opportunity, covering
recruitment and employment, promotions, team opportunities, and training programs. We are

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 committed to compliance with all laws and regulations relating to equal employment opportunity,
affirmative action, harassment, and diversity.

Respect and fair treatment

All personnel are expected to treat their colleagues with respect. Providing a safe, healthy, and
productive work environment is a priority, and you are expected to support efforts to eliminate any
actions or circumstances that undermine such an environment. Unlawful discrimination, verbal or
physical harassment or abuse, or offensive behaviour (whether or not sexually related) by
personnel, agents, or clients of Deloitte SEA will not be tolerated.

Personal relationships

From time to time, personal relationships, romantic or otherwise, may exist or develop between
two people employed by Deloitte SEA or with an employee of a client organisation (attest or
nonattest clients). Such relationships can pose serious independence or conflicts of interest issues,
either in fact, or in appearance, in the minds of the public, our clients, or our colleagues. We
recognise that these types of relationships may occur and appropriate notification or assignment
steps may need to be taken to prevent such relationships from resulting in a professional issue for
the firm, or the individuals involved. Such relationships must be reported by the persons involved
to the appropriate office, service line leader or practice entity head who will then consult with the
Human Resources department to determine what, if any, notifications or assignment changes need
to be made.

Licensing and professional certifications

In order to deliver on our promise of exceptional client service and to comply with relevant
regulations, many of our professionals maintain professional licenses and certifications (e.g., Audit
License, Liquidator’s License, Capital Markets and Services License). All personnel holding
professional licenses and certifications have a personal responsibility to maintain such licenses and
certifications in good standing through timely renewals, and (where required), the attainment of
the appropriate level of continuing professional education.

Consultation

We are committed to a consultative culture. As a minimum, consultation on non-routine or

emerging issues or practices is not only expected, it is required. Frequent consultation with
national office and industry resources is encouraged. Deloitte SEA speaks with one voice on
technical and other practice-related matters. No individual partner, executive director, principal,
director or employee is permitted to ignore a technical or other practice related determination
rendered by a professional practice director, regional professional practice director, national
industry or service line leader, or the Reputation and Risk Group. Deloitte SEA has an established
procedure and protocol to allow any professional the right to appeal and resolve any professional
disagreements that might arise. As professionals, we have a duty and an obligation to express
differing points of view and appropriately resolve such matters in an open-minded and
professional manner.

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Health, safety and the environment

We are committed to providing a safe working environment for all personnel.

We are expected to discharge our responsibilities and perform our duties in a professional manner
in the workplace (or anywhere else) while conducting business. Clients — as well as the general
public — expect us to provide quality, professional services while being free from the effects of
drugs, alcohol, or other substances that may hinder job performance or judgment. The illegal use,
sale, dispensing, distribution, possession, or manufacture of illegal drugs or other controlled
substances by a partner, executive director, principal, director or employee is prohibited and is
cause for termination or suspension.

On occasion, there may be events where the management approves the serving of alcoholic
beverages. In these cases, all appropriate liquor laws must be followed, including laws regarding
the serving of alcohol to those under the legal drinking age. Consistent with our policy,
intoxication and excessive drinking at these events are cause for disciplinary action including
termination or suspension.

We each are responsible for our own safety, and that of our colleagues, in the workplace. The
workplace should be free from violent and abusive behaviour. Threatening, aggressive, or abusive
behaviour towards fellow colleagues or others in the workplace will not be tolerated. Explosives,
firearms, or other weapons, whether legally permitted or not, are not allowed in any of the
facilities of Deloitte SEA.

Whistle blowing

The work environment requires our people to blow the whistle in some instances. It is necessary to
report any signs of negligence, abuses or dangers that might result in serious personal, commercial
or social damage. If our superiors do not act to curtail or mitigate such negligence, abuses or
dangers, it may be necessary to ‘blow the whistle’ to help correct the problems or reduce the risk.

The Community. We commit to contributing to society as a role model for positive change

PUBLIC INTEREST
Anti-corruption

We are against corruption in any form and stand firmly against bribery in order to contribute to
good governance, economic development, and the improvement of social welfare wherever we do
business. We are also committed to working in an ethical, lawful, and professional manner as set
forth in the DTTL Policies Manual and the Deloitte SEA Anti-Corruption Policy and Guidance.
All personnel are prohibited from paying and accepting bribes including inducing or permitting
any other party to make or receive bribes on their behalf. Bribes include political contributions,
charitable contributions, facilitation payments, gifts, entertainment and hospitality which may be
construed as a subterfuge for bribery.

Money laundering
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 It is the obligation of everyone in Deloitte SEA not to commit money laundering offences. We are
committed to complying with all applicable laws and regulations concerning anti-money
laundering efforts. Deloitte SEA’s integrity and reputation can be severely damaged by failing to
detect and avoid relationships that place us at risk. We will conduct business with clients of good
reputation who are involved in lawful business activities. We will not knowingly accept funds that
are derived from unlawful sources or activities.

Government transactions and relations

Our business transactions frequently involve governmental entities. The laws and regulations
pertaining to doing business with governmental entities may include special rules and a more
stringent set of requirements, not typical of other businesses. For example, providing meals or
hosting social events may be acceptable for a “non-governmental” client. However, they may be
prohibited when a government employee is involved. All personnel involved in providing services
to governmental entities are required to adhere to the government’s ethical standards as they apply
to the services of the firm, as well as the SEA Code.

We comply with all applicable rules, laws, and regulations relating to the prohibition of political
lobbying or attempting to influence government officials.

All partners, executive directors, principals, directors and employees are free to support the
political process and their political beliefs. However, the inappropriate use of assets of Deloitte
SEA or any reference to the Deloitte name to support a political campaign is not permitted.
Individual political contributions made by partners, executive directors, principals, directors and
employees are personal decisions consequently personal expenses. Such contributions are not
reimbursable by Deloitte SEA.

International business

All DTTL member firms are committed to ethical business conduct in their global marketplaces.
Like all DTTL member firms, Deloitte SEA expects its personnel conducting international
business to know, understand, and abide by the relevant laws of the countries in which they do
business. Personnel should determine that payments made by or on behalf of Deloitte SEA are
lawful and are made only for legitimate business purposes. Under no circumstances is it acceptable
to offer, give, solicit or receive any form of bribe or kickbacks.

Gifts and entertainment

We strive to compete on the basis of the quality and value of our services. Personnel of Deloitte
SEA should not offer or accept gifts or payments, or undertake inappropriate activities, to facilitate
any engagement. Entertainment of our personnel or clients that is lavish or inappropriate in nature
is also not permitted.

In addition, you have an obligation to comply with our clients’ policies regarding gifts and
entertainment. Gifts or entertainment should not be accepted or extended by the firm’s personnel if
they could be reasonably considered to:

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 • Improperly influence Deloitte SEA’s / DTTL’s business relationship with, or create an
obligation to, a client, supplier, contractor, or alliance partner;

• Violate laws, professional standards and regulations, or the SEA Code;

• Constitute an unfair business inducement; or

• Cause embarrassment to or negative impact on Deloitte SEA and/or DTTL.

Neither you nor any member of your immediate family should use your position with the firm to
solicit any cash, gifts, or free services from any client, supplier, contractor, or alliance partner for
your or anyone else’s personal benefit.

Guidelines regarding gifts and entertainment that are acceptable:

• Nominal gifts that are usual and customary for the profession (e.g., pens, calendars, and
mugs);

• Reasonable invitations (may be either extended or accepted) to business-related

meetings, conventions, or conferences (e.g., a product training seminar, a business
luncheon or dinner); and

• Invitations to social, sporting, or other events (may be either extended or accepted) if the
cost is reasonable and attendance serves a customary business purpose (e.g., networking).

In all cases, you have a responsibility to know and understand the firm’s detailed guidance on
acceptable client entertainment, as well as the client’s own policies related to allowable gifts and
entertainment involving their personnel.

Supplier, contractor and alliance partner relationships

Our success depends on building productive relationships with all suppliers, contractors, and
alliance partners based on integrity, ethical behaviour, and mutual trust. Regardless of whether
there is an existing or future client relationship, we select suppliers, contractors, and alliance
partners based on the quality, price, service, delivery, and supply of needed goods and services.
Procurement decisions should be based on objective business rationale and not on personal interest
or bias.

Responsibility to society and community involvement

We have a responsibility to be a good neighbour and a contributing corporate citizen in the

communities in which our people work. We are committed to conducting our business activities in
ways that honour ethical values and respect people, communities, and the natural environment. We
will continue to work toward the sustainable improvement of life and business by:

• Rendering high-quality professional services with utmost integrity; and

• Providing a workplace that contributes to the professional growth, development, and

personal success of our people.

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 Our people share a long tradition of supporting the communities in which they live and work. In
addition to financial contributions made by Deloitte SEA and its people, many of our people also
volunteer their time to worthwhile causes. We actively encourage, support and reward
volunteerism for several important reasons:

• Helping others and sharing is simply the right thing to do;

• Community involvement is a manifestation of our shared values;

• A healthy community depends on the active involvement of all who live and work there;
and

• Community involvement helps people become better professionals by enhancing their

skills and leadership abilities outside the workplace.

In connection with the performance of client attest services by us, we will conduct, and possibly
limit, community activities, including the making of monetary donations, so that the obligation of
Deloitte SEA to maintain independence (both in fact and appearance) cannot be called into
question.

Truth in communications

Our people are committed to representing the firm with honesty and candour. Similarly, it is our
policy to communicate facts about our capabilities, policies, and people accurately and responsibly
in advertisements, sales, marketing, recruiting and all other promotional materials.

Social media

Social media exists both within and outside of Deloitte SEA entities and can be used for both
business and personal purposes. All personnel are expected to adopt the following guidelines when
dealing with social media:

Be true to yourself and others

When using social media, you should not do so anonymously or under a pseudonym, unless
specifically asked to do so (for example, in a Deloitte survey). If you have what could be
perceived as a conflict of interest in something you are discussing, be the first to point it out.
Speak in the first person and bring your own personality to the forefront.

Respect your audience

You should be mindful of how you present yourself and how you treat your audience. Express
your perspectives and show your personality, but always respect the audience.

Tend the community garden If you see something in social media that appears to violate the firm’s
policies or could be harmful to the Deloitte brand, it is your responsibility to address the issue by
notifying the original contributor; editing the content, if that is appropriate for the media you are
in; or reporting your concern. If you are a partner or director who is a community sponsor of
Deloitte-Internal or Deloitte-Public social media, it is your responsibility to monitor the activity
and content for appropriateness.
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Speaking on behalf of yourself

In personal social media, particularly if you might be identified as a Deloitte person, be sensitive
to the fact that your communications may be considered a position of the firm. Remember,
anytime that you can be identified as a Deloitte person, even in a non-business context, you are
impacting the way your audience views Deloitte.

Add value

Social media should be used in a way that adds value by helping you, your coworkers, or our
clients do their jobs and solve problems; increase knowledge or improve skills; contribute directly
or indirectly to the improvement of Deloitte SEA entities’ services and processes; or enhance the
strength of the firm.

The buck stops with you If you are about to publish something that gives you even the slightest
doubt, consult with the appropriate Deloitte SEA entities partner or director. Ultimately, though,
you are responsible for what you post or publish in any form of social media.

Consider perceptions

Be sure that your use of social media is consistent with how you wish to present yourself to
colleagues and to friends. If you make an error, acknowledge the error and correct it quickly.

Consider the future

What sounds great today to your targeted audience could tomorrow reach an unintended audience
with unexpected consequences. Consider the reach and longevity of the internet before you
publish.

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