Quality, ethics and anti-corruption

We’re focused on the issues of ethics, integrity and building trust in everything we do and also by working to generate the greatest impact we can on these issues which are at the heart of our business. This supports our CR strategy to be a catalyst for change in the relevant debates.

Every year, PwC’s UK firm organises the Building Public Trust awards to help raise standards of transparency in measurement and reporting practices for businesses. Several PwC firms also organise annual transparency awards for the non-profit sector.

PwC also carries out anti-corruption work with clients and contributes thought leadership on the topic. The PwC firms in the Czech Republic, Hungary, Russia, the US and the UK conduct advocacy and raise awareness through the forum, PwC Fraud Academy, covering fraud, corruption and integrity risks. The PwC Fraud Academy is a forum through which members can share knowledge and participate in research to help prevent, detect and investigate fraud and economic crime in all their many forms. Members receive technical updates on fraud prevention and detection issues as well as the opportunity to meet periodically with other PwC Fraud Academy members to exchange knowledge, ideas and experiences.

Our Global Code of Conduct: our approach to ethics within the Network

PwC’s Global Code of Conduct nurtures a culture that supports and encourages all PwC people to behave appropriately and ethically, especially when they have to make tough decisions.

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.

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 in the 157 continues in which we operate. This is no small task and requires large teams that focus solely on compliance issues.

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:

  • Independence
  • Ethics and business conduct
  • Assurance, Advisory and Tax risk management
  • Governance
  • Anti-bribery
  • Data protection and privacy

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. There are some common principles and processes to guide PwC firms in applying the PwC network standards. Major elements include the way we do business, sustainable culture, policies and processes, and quality reviews.

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 firms reinforce 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. These include the requirements around personal behaviour, services that may and may not be provided to audit clients, and business relationships / business partners. 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. This would include, where appropriate, discussion with the client’s audit committee regarding an evaluation of the impact of the breach on the independence of the firm and the need for safeguards to maintain objectivity. Although most breaches are minor and attributable to an oversight, breaches are taken seriously and investigated as appropriate.

Quality reviews

Each PwC firm is responsible for monitoring the effectiveness of its own quality control systems. This includes performing a self-assessment of its 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.