Complaints and Allegations Policy

Isla Lipana & Co. Complaints and Allegations Policy

Isla Lipana & Co., the Philippine member firm of PwC network has adopted a complaints and allegations policy wherein its partners and staff members can send confidential messages through its Ethics and business conduct and quality control database and helpline. Please read through for more information.

About the Ethics, business conduct and quality control database and helpline

What is the Ethics, business conduct and quality control database?

It is a database, which is an expanded version of the PH Ethics Database, through which partners and staff members of the firm could (a) send in confidential messages involving complaints and allegations against a PwC Philippines/ Isla Lipana & Co. partner or staff with respect to failure to comply with professional, regulatory, and legal requirements of PwC's own system of quality controls or (b) seek clarifications on firm policies and difficult issues or situations.

How is confidential messaging through the Ethics, business conduct and quality control (EBCQC) database accomplished?

A form available in the EBCQC database needs to be accomplished by the partner or staff member. Once this is done, a confidential e-mail is sent to our Territory Senior Partner.

Who can submit comments in the appropriate form to the EBCQC database?

Anyone in the Philippine firm of PricewaterhouseCoopers/ Isla Lipana & Co., including personnel on assignments outside the Philippines.

What is the Ethics, business conduct and quality control helpline?

It is a telephone hotline (845 29 39) which is put in place and available 24 hours a day, 7 days a week. Said helpline is used exclusively to receive complaints and allegations from third parties (clients, suppliers, regulators and others) against a PwC Philippines/ Isla Lipana & Co. partner or staff member, who may or may not disclose his/her identity. It can also be used by the firm’s partners and staff members who wish to remain anonymous but would want to seek clarification on certain issues or discuss complaints and allegations against firm partners and staff members. During office hours (8 am to 5 pm on weekdays, except holidays), a helpline representative will receive your call. A voice logger will be used to record all calls received during and after office hours.

What about confidentiality?

Every effort is made to preserve confidentiality. The name of the complainant who submits forms through the EBCQC database is disclosed among the Ethics and Business Conduct and Quality Control Office (EBCQCO) members only on a need-to-know basis and the email is not documented in one's personnel file. The forms accomplished and submitted are stored in the EBCQC database and not through Lotus Notes and cannot be accessed by others. The messages will only be delivered to the Territory Senior Partner who will identify the EBCQCO members who will have access to the same. The name of the caller shall likewise not be disclosed unless the caller chooses to disclose his/her identity and the files of recorded messages shall be restricted to EBCQCO members only.

All responses to queries raised including remedial action taken will be recorded in the database, which will be available only to members of the EBCQCO.

Matters pertaining to clients will be treated in accordance with the confidentiality rules and the rules of the Securities and Exchange Commission, Bangko Sentral ng Pilipinas and the Office of the Insurance Commission.

Do I have to go immediately to the Territory Senior Partner for my comments or queries?

You should use normal management channels first - your manager or the partner-in-charge of your unit or the risk management partner or ethics partner. If you are not comfortable, you do not know whom to ask or you are not satisfied with the results of your queries, you may submit forms through the EBCQC database or call the EBCQC helpline.

What types of issues do the EBCQC Database or the Helpline deal with?

The following questions or concerns may be relayed through the database or helpline as they relate to the performance of a professional service, such as:

  • Disagreement among individuals on the audit engagement team on practice-related matters;
  • Identification of a potential illegal act on the part of the company being audited which we have become aware of but have not responded to in accordance with PwC Audit 5660; and
  • Actions that violate PwC Audit policy such as changing dates, or deleting relevant emails or other documentation in the MyClient and other files which support any and all reports issued by the Firm with due consideration for the record retention policy of the Firm.
  • Any other questions pertaining to ethics and business conduct or quality control.

Does the issue need to be considered severe before I accomplish a form for the database or call the Helpline?

Your issue does not need to be considered severe in order for you to report it through the EBCQC database or through the helpline. The Territory Senior Partner (TSP) will then convene the EBCQCO board immediately to determine the appropriate action to take.

When can I reach the Helpline and what happens when I call?

The Helpline (845-2939) is available for use by partners and staff members and third parties during normal business hours (8 am to 5 pm) on weekdays, except holidays. Outside normal business hours, you can leave a recorded message which will be treated confidentially using the helpline.

How are situations resolved?

Many queries/calls of partners, principals and staff members are resolved by giving you advice; others require an investigation or other action. Calls from third parties could cover a broad range of topics. The EBCQCO will be assisted by advisors and subject matter experts in answering your question or resolving your problem. Allegations are discreetly investigated by qualified parties. When disciplinary action is called for, it is taken. The manner and severity of discipline is determined by firm policy and the nature and gravity of the offence and will range from verbal counselling to compensation adjustments and dismissal. Allegations and complaints coming from third parties will be studied and referred to the EBCQCO.

Do I have to give my name if I use the helpline?

If you make a call during the normal office hours in the Philippines, you may remain anonymous if you prefer to do so. If you do choose to remain anonymous, you will be asked to give a code and call back date and time. A call back date is given so that you have the opportunity to call back with any additional information on your original issue, as well as to receive a response provided by the EBCQCO in regard to your question or concern. However, if you do decide to provide your name, you will be referred to the appropriate specialists, who will make direct follow ups on a timelier basis and who will make every effort to protect your identity. If you happen to call beyond office hours in the Philippines, your message will also be recorded. Please ensure that you give the minimum information required (see last question below). You may also provide a code name and call back date and time so that you can be accordingly informed of the response.

Am I risking retaliation by sending an email or calling the Helpline?

PricewaterhouseCoopers/ Isla Lipana & Co. assures protection against any form of reprisal for reporting in good faith actual or suspe cted violations of our Code and other policies and, to the extent possible, makes every effort to protect the identity of anyone reporting this information.

How will I know if my situation has been resolved?

If you do decide to provide your name, a member of the EBCQCO will follow up with you to close the loop and answer any additional questions or concerns you may have. However, please be aware that privacy is respected for all parties involved and the EBCQCO member will generally not be able to provide you with specific details regarding the outcome of the situation, and what, if any, disciplinary steps were taken as a result. The EBCQCO does take every issue seriously and appropriate measures will be taken to ensure that your issue or concern is appropriately addressed.

What is the EBCQCO's lead time in resolving issues raised?

The policy is to resolve the same within three (3) working days from the time the issue has been raised, unless a lengthy investigation is called for.

What are the minimum requirements for anonymous reporting of complaints/ allegations?

If the complaint or allegation is done anonymously, there should be disclosure of the following minimum information:

  • Description of the complaint or infraction;
  • Name of the person or persons involved;
  • Date or dates of occurrence;
  • Indication as to whether or not the complaint has been brought to the attention of the LoS Partner/Leader involved, if applicable.