The misconduct occurred between 2016 and 2020, and saw 1,131 partners and staff – about 12 per cent of total staff – either share or receive answers during mandatory internal online training tests that covered topics including professional independence, auditing, and accounting.
The internal training program provides staff with technical instruction, furthers their professional development, and satisfies continuing professional education requirements.
The firm uncovered the misconduct in early 2020, leading to an internal investigation and disclosure to regulators, including the US Public Company Accounting Oversight Board (PCAOB), and ASIC.
As a result of its own investigations, KPMG moved to dock the pay of 16 partners and 30 staff, while the remaining 1,083 staff members received verbal or written warnings.
In a disciplinary order published on Wednesday morning, the PCAOB found that the sharing of answers was “widespread” within KPMG’s audit practice and “occurred at all levels of the firm”, with answers shared over email, text messages, hard-copy documents, and through word of mouth.
The PCAOB found that while the big four firm had in place certain quality control policies, these policies and procedures were inadequate to prevent or detect the extensive answer sharing on training tests.
In issuing its sanctions, the PCAOB acknowledged that the firm’s “extraordinary cooperation” in self-reporting the misconduct and implementing remedial measures had contributed to a lesser civil penalty.
KPMG Australia chief executive Andrew Yates said the misconduct was “totally unacceptable”, breaching its code of conduct and failing to align with the firm’s values.
“I’m disappointed because the conduct reflects on all of us,” said Mr Yates.
“Everyone at our firm is now absolutely clear that there are non-negotiable expectations of behaviour aligned with our values. Our partners and people understand that unethical behaviour has no place in the values-based culture at KPMG.”
According to Mr Yates, the firm has now required its partners and staff to complete a new independence test, and issued clearer and more prominent warnings about training and testing-related misconduct, and introduced enhanced monitoring to identify possible future misconduct.
“Looking forward, we will place greater emphasis on building, measuring and managing our culture – embedding behavioural expectations into scorecards to drive accountability,” said Mr Yates.
“Having a values-based performance conversation will be an important part of developing our people, and identifying potential for leadership roles.”
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