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Anti-corruption

Material topics 2015-2016 GRI Aspect DISCLOSURES ON MANAGEMENT APPROACH
Independence, integrity and ethical standards Anti-corruption a. Why is this Aspect material?
Independence, integrity & ethics and anti-corruption are of significant value to EY and its stakeholders, because they show how EY is able to remain professionally objective and independent in the services we deliver to our clients and so to the (business) society as a whole.
b. How does EY manage this Aspect or its impact?

Independence
See Quality and risk management and, with respect to
Ernst & Young Accountants LLP, to the EY NL Transparency Report 2015/2016/Independence practices.

Integrity & ethics
See EY NL’s integrity and ethics website. The Compliance Officer’s principal task is to monitor that Ernst & Young Accountants, its partners and employees maintain high standards of integrity and comply with the rules laid down by or pursuant to Sections 13 through 24b of the Dutch Act on the Supervision of Audit Firms (Wet toezicht accountantsorganisaties). See Transparency Report 2016.

Anti-corruption
Each individual carries personal responsibility for preventing and reporting any corrupt behavior. The Risk Management Leader is responsible for the execution of the strategic approach to corruption. The general counsel advises on risk management issues and is responsible for operational execution. For EY, the two most relevant forms of corruption are bribery and money laundering. EY has a global anti-bribery policy and in the Netherlands EY implemented a risk management policy in the context of the Dutch Money Laundering and Terrorist Financing Prevention Act (Wwft)

Anti-bribery
The Anti-bribery Global Policy provides our people with direction around certain unethical and illegal activities. It emphasizes the obligation of our people to comply with anti-bribery laws and provides greater definition of what constitutes bribery. It also identifies reporting responsibilities when bribery is discovered. In recognition of the growing global impact of bribery and corruption, efforts have been increased to embed anti-bribery measures across EY, and training is mandated for all our people.

Anti-money laundering
Regarding money laundering, we adhere to the Dutch Money Laundering and Terrorist Financing Prevention Act (Wet ter voorkoming van witwassen en financieren van terrorisme / ”Wwft”). In accordance with the Wwft we estimate risks associated with clients and engagements. A Wwft risk assessment is essential for the completion of the client and engagement acceptance.

This risk assessment procedure is laid down in the ‘Wwft Risk Policy’. The policy covers topics like client examination and reporting of unusual transactions. In the previous year, tools to collect and store client identity data were developed and implemented. Pursuant to the Wwft, EY is obliged to report any unusual transactions (transactions where facts and circumstances give rise to suspicion of money laundering or terrorist financing) to the Financial Intelligence Unit-Netherlands (a central reporting authority).
c. How do we evaluate the way we manage this Aspect?

Independence
See Transparency Report 2016 to read about our ethics processes.

Anti-corruption
The anti-bribery policy is regularly revised and updated in order to reflect changes in legislation and our own experiences. The most recent revision of the anti-bribery policy came into force on September 1, 2013. EY’s News Portal is used to inform our personnel about the current anti-bribery policy as well as the upcoming revisions and training.

Anti-money laundering
The Wwft Risk Policy has been regularly revised and updated since the Wwft entered into force. The policy is being kept up to date by our legal department. Our people, who are closely involved in the client and engagement acceptance, are required to complete a web-based course on the Wwft. In addition, any changes to the Wwft or our Wwft Risk Policy are communicated to our people via EY News Portal.