Independence is fundamental to our ability to serve our clients and the public interest. It gives our clients, regulators, and the public confidence that we act with integrity and objectivity. We provide our partners and staff with robust systems and tools to manage their independence responsibilities, including a dedicated team of full-time independence specialists. This team is responsible for developing independence policies and guidelines, and for helping our client service teams maintain independence according to regulatory rules and requirements. A U.S.-based call center is available for guidance on personal independence questions and other compliance requirements. Partners and staff are also required to complete comprehensive course work around independence, ethics, and compliance on an annual basis.
Questions involving independence compliance are generally identified by the affected partner or other professional and through the firm’s audits of individuals’ personal independence compliance. When we determine a matter of noncompliance exists, we address and resolve the matter promptly. Resolution includes discussing the matter with the audit committees of companies for which U.S. Securities and Exchange Commission (SEC) and Public Company Accounting Oversight Board (PCAOB) independence requirements apply. In FY13, we concluded, and the respective audit committees agreed, that none of the noncompliance matters we identified involving SEC and PCAOB independence requirements compromised our objectivity. Accordingly, none of those instances was of a nature that required us to resign (or caused the audit committee to ask us to resign) as the auditor.