Committed to transparency

Each PwC firm conducts objective quality control reviews of all of its services.

Each PwC firm is required to have a partner responsible for independence matters, supported by adequate and trained resources.

We are constantly seeking ways to provide greater clarity about who we are, what we do and how we do it. We recognise the impact our business has on our stakeholders, the capital markets and the communities in which we live and work. And it matters to us that we engender confidence in the entire PwC network by putting the principle of transparency into practice.

We believe that the key factors that differentiate PwC among the world’s leading professional services organisations are the talent of our people, the breadth of the PwC network and the standards with which PwC firms comply.

These standards cover important areas such as service quality, governance arrangements, independence, risk management, people and culture, and brand and communications. PwC firms agree to follow network standards and their compliance with these standards is monitored regularly.

Legal structure, ownership and network arrangements

Network arrangements and member firms

In most parts of the world, the right to practise audit and accountancy is granted only to firms that are majority-owned by locally qualified professionals. PwC is a global network of separate firms, operating locally in countries around the world.

PwC firms are members of PricewaterhouseCoopers International Limited and have the right to use the PricewaterhouseCoopers name.

As members of the PwC network, PwC firms share knowledge, skills and resources. This membership enables PwC firms to work together to provide high-quality services on a global scale to international and local clients, while retaining the advantages of being local businesses – including being knowledgeable about local laws, regulations, standards and practices.

PricewaterhouseCoopers International Limited

PricewaterhouseCoopers International Limited (PwCIL) is a UK private company limited by guarantee in which PwC firms are members. PwCIL acts as a coordinating entity for PwC firms and does not practise accountancy or provide services to clients. PwCIL works to develop and implement policies and initiatives to create a common and coordinated approach for PwC firms in key areas such as strategy, brand, and risk and quality.

PwC firms can use the PwC name and draw on the resources and methodologies of the PwC network. In return, member firms are required to comply with certain common policies and the standards of the PwC network.

Standards and internal quality control systems

Every PwC firm is responsible for its own risk and quality performance and, where necessary, for driving improvements. Each PwC firm is also exclusively responsible for the delivery of services to its clients.

To support transparency and consistency, each PwC firm’s Territory Senior Partner signs an annual confirmation of compliance with certain standards. These cover a range of areas, including independence, ethics and business conduct, Assurance, Advisory and Tax risk management, governance, anti-bribery and data protection and privacy.

These confirmations are reviewed by others who are independent from the PwC firm in question. Member firms are required to develop an action plan to address specific matters where they are not in compliance. The action plans are reviewed and their execution monitored.

There are some common principles and processes to guide PwC firms in applying the network standards. Major elements include:

The way we do business

PwC firms undertake their business activities within the framework of applicable professional standards, laws, regulations and internal policies. These are supplemented by a PwC Code of Ethics and Business Conduct for their partners and staff.

Sustainable culture

To promote continuing business success, PwC firms nurture a culture that supports and encourages PwC people to behave appropriately and ethically, especially when they have to make tough decisions.

PwC people have ready access to a wide array of support networks within their respective firms – both formal and informal – and technical specialists to help them reach appropriate solutions. The foundations of PwC’s culture are objectivity, professional scepticism, cooperation between PwC firms and consultation.

Policies and processes

Each PwC firm has its own policies, based on the common standards and policies of the PwC network. PwC firms also have access to common methodologies, technologies and supporting materials for many services.

These methodologies, technologies and content are designed to help a member firm’s partners and staff perform their work more consistently, and support their compliance with the way PwC does business.

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 a member firm’s 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.

For Assurance work, there is a specific quality review programme based on relevant professional standards relating to quality controls including International Standard on Quality Control 1: ‘Quality Control for Firms that Perform Audits and Reviews of Financial Statements, and Other Assurance and Related Services Engagements’ (‘ISQC1’) and where applicable, the PCAOB Quality Control Standards.

The overriding objective of the assurance quality review programme is to assess for each PwC firm that:

  • quality management systems are appropriately designed, are operating effectively and comply with applicable network standards and policies
  • engagements selected for review were performed in compliance with applicable professional standards and PwC Audit requirements, and
  • significant risks are identified and managed appropriately.

A member firm’s assurance quality review programme is monitored, as is the status and effectiveness of any quality improvement plans a PwC firm puts in place.

Safeguarding our independence

Policy and resourcing

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, 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 PwC firms have agreed to comply. The policy is supported by detailed guidance on the rules and principles to be applied in evaluating the provision of non-audit services to audit clients.

PwC firms impose supplementary independence restrictions and processes by reference to local regulatory and ethical requirements, when necessary. These may have cross-border effect.

Each PwC firm is required to have a partner responsible for independence matters, supported by adequate and trained resources.

Training

Each PwC firm is responsible for developing and implementing an appropriate independence training plan for its partners and practice staff, including the requirements around personal interests and relationships, services that may and may not be provided to audit clients, and business relationships. The network provides illustrative materials for use by PwC firms.

The Assurance, Tax and Advisory lines of service also provide training and other materials dealing with independence considerations related to the provision of non-assurance services.

Compliance processes

Our compliance processes rely on a combination of business activities, controls and monitoring systems.

Our network has detailed policies and processes to evaluate the potential impact of a proposed non-audit service on the reporting PwC firm’s independence.

PwC firms are required to obtain authorisation from the group audit engagement partner regarding the provision of non-audit services to entities on the ‘Independence List’. Authorisation is only given after careful analysis of whether the service could impair the reporting firm’s independence by reference to policy requirements and external regulatory requirements, including an evaluation of threats to independence and available safeguards.

Partners and client-facing managers in all PwC firms are also required to record the details of their investment portfolios on a confidential database that provides real-time monitoring of the permissibility of investments held against an ‘Independence List’ of prohibited securities.

Joint business relationships are evaluated for compliance with any relevant regulatory requirements and for any threats to independence, and are required to be approved, recorded and regularly monitored for changes that may impact the independence assessment. Similarly, any independence implications raised by proposed acquisitions by PwC firms are evaluated and addressed to maintain compliance with any relevant regulatory requirements.

As well as these and other independence compliance- monitoring systems, PwC firms operate a number of confirmation and verification processes that provide information relevant to independence compliance, such as:

  • annual compliance confirmations by partners and practice staff, and
  • inspection and compliance-testing programmes at firm and engagement levels. Such inspections look at, among other things, compliance with the requirements relating to partner rotation and partner evaluation and compensation.

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, all breaches are taken seriously and investigated as appropriate.

Those charged with governance

PwC firms recognise the importance that those charged with governance – including audit committees – play in overseeing the auditor’s independence, including overseeing the nature of other services that they provide and the fees payable. PwC audit teams work closely with those charged with governance on public company audits and have regular dialogue on matters that may be seen to influence independence, including the provision of other services.

Partner remuneration

An essential element of PwC’s ethos is a set of common principles for remuneration of partners in PwC firms, based on partner performance and quality of work.

The underlying premise of the partner income philosophy is to encourage, recognise and reward partners, both as individuals and as members of teams. Reward is based on their contribution to their respective firms and, where relevant, to the wider network. Quality is the most important measure in assessing a partner’s contribution.

Continuing education

With some 86,000 Assurance people across the firms in the PwC network, the task of providing continuing education throughout each professional’s career is a major challenge. Mechanisms are in place at the network level to support PwC firms in achieving this goal.

The PwC approach to Assurance learning and education (L&E) is to provide access to a formal curriculum of technical courses, while also providing support for PwC firms’ L&E leadership and fostering personal accountability for continuing education.

PwC firms are committed to delivering quality audits around the world. To support them and to maximise consistency in the network, the formal curriculum provides access to courses covering:

  • the PwC Audit approach and tools
  • updates on auditing standards and their implications, and
  • areas of audit risk and engagement quality.

This formal learning is delivered in various formats – including webcasts presented by specialists, computer-based e-learning using videos and avatars, and classroom courses. All of these programmes support PwC’s focus on audit quality and provide practitioners with the opportunity to sharpen their professional judgement, scepticism, and technical and professional skills.

PwC firms provide additional formal training on professional skills and informal training in the way of guidance, tools, engagement team workshops and forums for staff to share their experiences in order to support them on the job. The informal training is supplemented with learning from others, whether by receiving and discussing feedback, or by observing and working with others.