Guidance for an immediate family member of a Deloitte employee in Denmark

If a member of your family works for Deloitte, you may already be familiar with the term “personal independence”.

The purpose of this site is to help you understand why you are being asked to comply with the same financial independence requirements as your family member who works at Deloitte, and to help you have a better understanding of the concept of personal independence, which is a key component of meeting our professional responsibilities.

What you will see, as you click on the buttons below; is that the personal independence regulations do not only apply to Deloitte professionals but also to you, as their immediate family member. Please do explore the information below to find out more.

Independence can be described as integrity, professional skepticism, intellectual honesty, objectivity, and freedom from the conflicts of interest both in fact and in appearance.

On a practical basis, for Deloitte, independence means maintaining integrity and objectivity with regards to the entities that we audit, both from the services we provide as a Firm but also through the personal financial relationship our people and their immediate family members hold. This is known as ‘personal independence’.

The act of ‘Independence’ is required for the firm as a whole, as well as for all individuals working at Deloitte – not just individuals within the Audit department. Depending on the role of a Deloitte professional, holding a financial relationship and/or interest in an audit client may create a “self-interest” threat—affecting independence with regard to that client.

Independence is enforced by regulators through audit legislation, regulations, and professional standards, such as the Danish Auditors Act and the international ‘IESBA Code of Ethics’ for accountants. By complying with the independence requirements, we satisfy the expectations of our regulators whilst also maintaining the trust of our clients and the public and protecting Deloitte's reputation. It is effectively Deloitte’s license to do business and getting it wrong can result in fines, loss of reputation and potentially disciplinary action against the individuals involved. We therefore expect all Deloitte professionals to take accountability for complying with the independence rules at all times.

It can be difficult to isolate your financial relationships and interests from that of your family member working at Deloitte. Our regulators view immediate family members as equivalent to the Deloitte professional in many situations. Audit firms are therefore required to be aware of, consider and monitor the financial relationships and interests of immediate family members, irrespective of whether they have joint or separate financial affairs.

It makes no difference if your family member works in Audit, Consulting, Tax, or any other of the business areas within Deloitte - the independence requirements will apply to you as well. 

What are my responsibilities?
Given that independence can be impacted by our financial arrangements and employment relationships, we ask you to take a number of actions to help us maintain our independence.

1. Consult

Consult with your Deloitte family member before you consider acquiring a new financial interest or changing an existing financial relationship so that they can evaluate if the financial relationship or interest is permissible under Deloitte’s independence policies. This is referred to as “pre-clearing”.

For example, consult before:

1. Buying a stock, bond, mutual fund, ETF, digital asset, or alternative investment

2. Granting trading authorization to an investment broker or advisor

3. Changing an existing or enrolling in a new pension plan

4. Being named as an executor or trustee, or accepting power of attorney over someone else’s financial matters

2. Report new investments

For Deloitte employees that are on managerial level and above, there is a requirement to record new financial investments (including those of Immediate Family Members (IFMs)), within 10 days of acquisition, on the firm’s compliance system – the Global Independence Monitoring System (GIMS). This also includes situations where you have control or influence over the assets of someone else. Therefore, please inform your Deloitte family member immediately when you acquire a new investment.

This system allows us to demonstrate and monitor that we, as individuals and as a firm, remain independent from our audit clients.

An Immediate Family Member (IFM) is, for independence purposes;

• Husband or wife
• Civil partner
• Financial dependents, including children and parents who receive 50% or more of their income from you and your spouse
  
• Spousal equivalent – someone who resides continuously in the same residence as you (this may vary across more than one property) and shares a committed relationship with you that is similar to a married couple/civil partnership, but you and the cohabitant are not married or cannot legally marry
  

If any of the above conditions apply – then the individual would be considered an IFM.

If you were not considered an IFM when your current spouse joined Deloitte, remember that once this changes, and you do become a spouse (or equivalent), that is when the independence policies will apply to you.

Audit clients, their affiliates and any other clients for which the Firm has to maintain its independence are known as "restricted entities".

The personal independence rules vary depending on the grade of your family member working at Deloitte. For instance,

• If they are a manager, you cannot invest in an audit client that the manager provides services to.
• If they are a partner, you cannot invest in shares, bonds or other securities issued by entities audited by Deloitte globally.
  

If you, as an IFM, wants to invest in a particular entity, you should first verify whether it is restricted for the Deloitte individual, based on the rules and the scope of their role. We refer to this process as pre-clearance.

If it is restricted and impermissible for that individual, you should not acquire the financial interest or enter into a financial relationship with that entity.

Similarly, if an individual has an existing financial investment or relationship and that company becomes restricted for them - you may need to dispose of the investment or take other actions to resolve any outstanding independence issues. You should be aware that a resolution might result in you having to take a loss on an investment.

Types of investments which are covered by our independence policies include, for example:

• Shares
• Mutual funds, such as equity funds and bond funds
• Funds held in personal pensions and in employment pension schemes (both from current and former employers)
  
• Debt securities like bonds and certificates
• Share options as part of employee share schemes
  

Other financial relationships are also considered, such as

• Bank and securities accounts
• Insurance products
• Loans and mortgages
  

Please be aware that the rules apply to any assets under your control or influence, for example held via an active Power of Attorney or a family-owned investment company.

To ensure on-going compliance, it’s important that you regularly monitor your existing financial relationships for any changes that might occur and inform your Deloitte family member about new acquisitions. They are required to report your investments in their GIMS account within 10 business days of purchase.

An area of independence which impacts many Deloitte professionals is the employment relationships of their spouses, their dependents and their close relatives.

In addition to IFMs, we need to consider close relatives - including parents, stepparents and siblings, when considering employment relationships.

These rules do not normally apply to your own close relatives, only those of the Deloitte professional.

Does it matter where you work?

It could matter, it all depends on the role of the Deloitte professional and the role you have with your own employer.

If you are employed by a restricted entity, your Deloitte spouse must disclose this as early as possible to the Personal Independence team. We can then analyze the facts and circumstances to see if there could be a conflict under any of the regulatory rules that apply to that specific client and provide you with the advice and guidance that you need.

What would we consider in our analysis?

Different aspects of your employment and circumstances can impact independence - for example:

• What type of position you have
• Whether your Deloitte spouse will provide services to the client - or its affiliates, or is in the Chain of Command of the Firm.
  
• Whether or not you have an employee pension plan with or investments in, the restricted entity (such as company shares)
  

To ensure your Deloitte family member stays compliant, it is important to be mindful of the requirements all of the time. Should you become aware of a situation where you omitted to notify your Deloitte family member, please do so as soon as possible. It is still better to be late than to not take any action. Also observe that changes can occur in your holdings without you initiating them (for example mergers of funds or also in some cases replacements of fund).

Below you will find some examples of life events and scenarios that could potentially impact independence.

Starting a new job
When you start a new job, you will likely be enrolled into the employee pension scheme and any individual mutual funds or other securities held within the scheme must be checked for permissibility and recorded in GIMS. If your employer is a publicly traded company and you receive benefits such as employee stock/options, these are also subject to Deloitte’s investment rules and reportable in GIMS.

Gaining a dependent
Whether it is the birth or adoption of a child or gaining a dependent because you are starting to care for an elderly parent or a sick relative, an addition to your family could have a significant impact on your financial relationships. Everything that these individuals have are attributable to the Deloitte professional and must be in compliance.

Stock spin-offs and mergers
Be aware of upcoming mergers or spin-offs in relation to your investments. You may receive a financial interest without your involvement. Regularly check your e-box for messages regarding changes to your stocks and inform your Deloitte family member about any changes.

Taking on a Power of Attorney (POA)
If you take on the role as a Power of Attorney where you have legal authority to make decisions about the principal’s property and/or finances, the assets held in the POA will be subject to the same independence rules that apply to you once it is activated.

Inheritance
If you inherit investments, consider if they are “publicly available” and therefore reportable in GIMS. If an impermissible financial interest is received unintentionally, for instance by way of inheritance or a gift, and such financial interest would not otherwise be permitted under Deloitte’s independence policy, then it must be disposed of as soon as possible.

A relative invests on behalf of your child
Make sure that relatives or friends that would like to give a stock, mutual fund or other security as a gift to your child, do not invest without consulting with the Deloitte family member first.

Assistance

Permissibility must be determined before acquiring a new investment, entering into a new financial relationship or making changes to an existing financial relationship.

We have a dedicated team to help you get this right. If you are in any doubt about our independence rules or how they impact you, please discuss with your Deloitte family member and they can consult with the Personal Independence team.

You can contact Nordic GIMS Support directly to get assistance with recording a new investment in your Deloitte family member’s GIMS account.