To assist with reporting personal financial interests, we have arrangements with more than 50 brokerage firms in the United States that provide an automated feed from a securities account directly into our monitoring system (they provide the holdings only—not the value or number of shares). Our professionals and their spouses and dependents are required to maintain their accounts at one of these participating firms and enable the data feed. If you have accounts with another firm, you will have 30 days to transfer the accounts upon joining.

Investments held within a benefit plan for a current or former employer are attributable to you if you have the ability to direct the investments. Once you, your spouse, or dependent leave a company, the assets in those plans should be rolled over into a current employer plan or an IRA with one of our participating brokerage firms. Professionals have 60 days upon joining Deloitte to initiate the process and 90 days to complete the rollover.

If you have any type of outside employment or activity whether paid or unpaid, inform your recruiter before you start working at Deloitte so you can start the approval process. Even a part-time job where you only work seasonally or for a couple hours a month could create an independence conflict in certain situations. As part of the approval process, we will consider whether your employer or the work you perform is affiliated with any audit clients.

During your first month with Deloitte, you will report many of your financial relationships in our monitoring system. If any of these are associated with an audit client, you will receive a notification. In some cases, based on your level, role, and office location, you may be able to clear the notification and retain the financial relationship. In other cases, you will be notified that you are unable to clear it and must divest promptly.

Several types of financial relationships are covered by our independence policies, such as loans, insurance, brokerage accounts, benefit plans, stocks, and mutual funds.

• Depository accounts such as checking/savings accounts, certificates of deposit, salary accounts, post office savings accounts, and cash balances associated with a health savings account (HSA)
• Broker-dealer/securities accounts (including Demat accounts, retirement [IRA], health savings accounts, and trust accounts)
• Public and private securities including stocks/shares, bonds/debentures, mutual funds (including funds held in a Systematic Investment Plan, or SIP), unit investment trusts, 401(k) investments, hedge funds, stock options, warrants
• Stock option, profit sharing, or stock purchase plans with a current or former employer
• Loans including mortgages/home loans, student loans, margin loans, and secured/unsecured (personal) loans
• Insurance products including property and casualty (e.g., homeowners', renters', and car/motorcycle/boat insurance), life, health, disability, and long-term care insurance
• Digital assets (including cryptocurrencies, stablecoins, and tokens of any kind) and digital wallet hosting services
• Financial relationships held within accounts, trusts, or estates for which you are named or acting as power of attorney or executor, administrator, or trustee 
• Variable insurance policies or annuities/unit-linked insurance plans (ULIPs)—including all underlying public and private investments
• College savings plan (529 plans) established by you, your spouse, or dependent
• Trusts in which you, your spouse, or dependent are named as a trustee or beneficiary
• Inheritances
• Credit cards with outstanding balances above $10,000
• Uniform Gifts to Minors Act (UGMA) and Uniform Transfers to Minors Act (UTMA) accounts

In addition to their own employment relationships, professionals should be aware of those of both their immediate families (spouse and dependents) and their close relatives (including parents, step-parents, and siblings) as there could be independence considerations.

• The following relationships held by a Deloitte professional or their immediate family member:
• • Former and/or current employer 401(k) plans or similar employee benefit plans (divestiture of prior employer benefit plans of a professional and/or an immediate family member is required to be initiated within 60 days of 1) a new professional joining Deloitte or 2) an immediate family member leaving an employer)
  • Severance or any other payments (bonus, 401(k) contribution, etc.) being received from a previous employer
  • Vested pension with a previous employer
• The following relationships held by a Deloitte professional, an immediate family member, or a close relative:
• • Serving in an accounting, financial reporting, or other significant role at an organization 
  • Serving as an officer or member of a board of directors or audit committee (whether for pay or not)
  • Working for an audit client
  • Working for a professional services firm or providing professional services as an independent contractor

Our approval process for outside employment and activities, including volunteer work at nonprofit organizations, applies only to Deloitte professionals, not their family members. Approval through your recruiter should be obtained before starting with Deloitte.

• Non-Deloitte employment, such as part-time employment (e.g., retail store, fitness instructor), self-employment, family business, or any other type of paid position
• Community activities/community leadership positions (paid or unpaid)
• Advisory boards
• Professor/instructor roles
• Professional services provided independently or through another firm (e.g., sales- or commissions-based activities, tax or advisory services, or independent contractor services)

Other business relationships can include closely held investments such as investing in a business or going into business with friends/relatives. Examples:

• Partnerships
• Joint investment (e.g., partnership interest, vacation home, boat, airplane)
• Ownership of a personal business
• Leasing space to/from a restricted entity (i.e., rent)
• Member of an investment club