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PwC's Code of Conduct nurtures a culture that supports and encourages all PwC people to behave appropriately and ethically.
The foundational elements of our culture are independence practices and compliance. Our Code of Conduct demonstrates our values in action and includes a strict anti-bribery standard that it is unacceptable for our people to solicit, accept, offer, promise or pay bribes. This is further supported by our Global Anti-bribery policy and a confidential facility to allow our people to raise any concerns about ethics and business conduct.
Our policies, practices and culture support transparency within our business. Each PwC firm’s Territory Senior Partner signs an annual confirmation of compliance with certain Network standards. These cover a range of areas, including:
These are reviewed by others independent of the PwC firm in question, and firms are required to develop a remediation plan if they are not in full compliance.
In particular, objectivity is the hallmark of our profession, at the heart of our culture and fundamental to everything we do. Independence underpins objectivity and has two elements: independence of mind and independence in appearance. PwC reinforces both of these elements through a combination of setting the right tone from the top; independent consultation on judgemental issues; detailed policy requirements including prescribed processes to safeguard independence; regular training; and careful observance of independence requirements.
PwC's Global Independence Policy – based on the International Ethics Standards Board for Accountants’ Code of Ethics for Professional Accountants – contains minimum standards with which all PwC firms have agreed to comply. These relate to assurance clients, including the adoption of processes and safeguards designed to maintain independence from such clients.
PwC firms impose supplementary independence restrictions and processes by reference to local regulatory and ethical requirements, when necessary. Each PwC firm is required to have a partner responsible for independence matters, supported by adequate and trained resources, to support the relevant PwC firm and its people in complying with policy requirements. This includes providing a resource to consult on policy interpretations and practice matters.
Training programmes on the PwC Global Independence Policy and related independence processes are available to all PwC firms. Each PwC firm is responsible for developing and implementing an appropriate annual independence training for its partners and practice staff, making appropriate use of global materials, supplemented with additional content tailored to reflect local requirements. New joiners, irrespective of which PwC firm and part of the practice they join, receive training on the PwC Global Independence Policy.
PwC firms are required to have disciplinary policies and mechanisms that promote compliance with independence policies and processes, and to report and address any breaches of independence requirements which, even with the control processes outlined above, may occasionally occur.
PwC takes responsibility for monitoring the effectiveness of our quality control systems. This includes performing a self-assessment of our systems and procedures and carrying out, or arranging to have carried out on its behalf, an independent review.
In addition, the Network monitors PwC firms' compliance. This includes monitoring not only whether each PwC firm conducts objective quality control reviews of all of its services, but also includes consideration of PwC firms' processes to identify and respond to significant risks. In accordance with applicable regulatory requirements, each firm may also be reviewed periodically, in some cases annually, by national and international regulators and/or professional bodies.
We operate in a highly regulated environment and are ever diligent to make sure we remain compliant with the rules and regulations of our industry and our clients’ industries.