Organisation, structure and standards

Being open about how the PwC network is organised and governed, and the high standards that we expect all PwC firms to follow, is important to us.

We understand the impact that our work can have on our stakeholders, the capital markets and the communities in which we operate. Therefore, we wanted to share some detail about our legal structure, our policies on independence and remuneration.

We believe that the key factors that differentiate PwC from our competition are the talent of our people, the breadth of the PwC network and the standards with which PwC firms comply.

Doing the best we can across the world is essential to delivering the right solutions for PwC's clients and stakeholders and maintaining PwC's reputation for excellence.

 

Network standards, policies and governance

To support transparency and consistency, each PwC member firm’s Territory Senior Partner signs an annual confirmation of compliance with PwC's standards. These confirmations cover a range of areas, including independence, ethics and business conduct, enterprise risk management, governance, anti-corruption, anti-money laundering, anti-trust, insider trading and information protection. In addition, member firms are required to confirm compliance with other business related standards (i.e. strategy and alignment, leadership and management, people, brand, technology, investment, serving clients).

Confirmations are reviewed and member firms are required to develop an action plan to address specific matters where they are not in compliance. The action plans are also reviewed and their execution monitored. Individuals are also required to complete Annual Compliance Confirmations indicating their understanding of, and compliance with, these policies.

There are some common principles and processes to guide PwC member firms in applying PwC's standards. Major elements include:

 

The way we do business

PwC member 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 Conduct applicable to all of their partners and staff.

Sustainable culture

To promote continuing business success, PwC member 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.

Policies and processes

In addition to the common standards and policies of the PwC network, PwC member firms also have access to common methodologies, technologies and supporting materials for many services.

These methodologies, technologies and materials are designed to help member firms, partners and staff perform their work more consistently, and support their compliance with the way PwC does business.

Conflicts of Interest

Given the broad nature of our operations and the many clients that we serve PwC does face risks of potential conflicts of interest. We take any potential conflict of interest very seriously and if a conflict is identified we take immediate steps to resolve or remove it. PwC maintains  internal controls and processes to ensure we identify potential conflicts, comply with relevant regulations, and act in accordance with PwC codes of conduct and frameworks for ethical decision-making at both a country and network level.

 

Managing independence

As auditors of financial statements and providers of other types of professional services, PwC firms and their partners and staff are expected to comply with the fundamental principles of objectivity, integrity and professional behaviour.

In relation to assurance clients, independence underpins these requirements. Compliance with these principles is fundamental to serving the capital markets and PwC's clients.

PwC has implemented policies and processes based on the ISQC1, issued by the International Accounting and Auditing Standards Board, the Code of Ethics for professional accountants issued by the International Ethics Standards Board for Accountants (IESBA), and, where applicable, the rules and standards issued by other regulatory authorities, such as the US Securities and Exchange Commission, the PCAOB and the European Commission.

These policies and processes are designed to help PwC comply with relevant professional and regulatory standards of independence that apply to the provision of assurance services.

Where other local standards go beyond the international requirements, compliance with those standards is also required of the member firm in that jurisdiction.

Each PwC firm has a designated partner with appropriate seniority and standing, typically supported by other specialists, who is responsible for managing the independence processes and providing support to the business. Compliance processes rely on, among other things, a combination of business activities and monitoring systems.

 

Managing independence requirements

PwC maintains a system identifying entities which are subject to independence requirements for PwC firms and their partners and practice staff. This drives many of PwC's controls and processes and assists in determining the independence status of entities before a PwC firm enters into a new non-audit engagement or business relationship.

Firm and personal relationships independence requirements apply to the interests and relationships of each PwC firm and to partners, as well as to practice staff involved in providing services to an assurance client or its related entities. The independence requirements are set out in the PwC Independence policy. Key controls include:

  • Monitoring of investments acquired and held by each firm, partners and practice staff managers.
  • Annual independence compliance confirmation – every partner and practice staff member is required to complete an annual confirmation of their compliance with all aspects of the independence policies, including personal independence
  • Personal Independence Compliance testing – all PwC firms conduct personal independence compliance testing, on a random sample basis, as a means of testing compliance with personal independence policies
  • Approval of joint business relationships – before a PwC firm enters into a new joint business relationship, it must evaluate it for compliance with the PwC independence policies. All PwC firms are required to periodically review such joint business or financial relationships to ensure their ongoing permissibility.
  • A rotation tracking system which monitors compliance with requirements relating to the rotation of audit engagement leaders and other key audit partners.

 

Controls over non-audit services

Before providing non-audit services to entities that are subject to independence restrictions, all PwC firms are required to use a network system to obtain authorisation from the group audit engagement partner responsible for services to that entity (or a related entity).

To assist this process and promote understanding of the independence requirements that apply, PwC has developed a comprehensive set of policy and supplementary guidance documents which address the provision of non-audit services to audit clients and their related entities. These documents are based on the provisions of the ‘IESBA Code of Ethics’, as well as the rules and standards issued by other regulatory authorities. PwC firms supplement this for local standards.

 

Consultation and training

Consultation by engagement teams on independence issues is embedded in the PwC culture. Teams are encouraged to consult with independence experts when a matter is complex, where the facts and circumstances of a situation suggest more than a single conclusion may exist, or in the case of doubt.

PwC's processes are supported by training of partners and staff. All PwC firms are required to develop and implement a training plan to provide partners and practice staff with annual or ongoing training relating to independence appropriate to their position and role.

 

Monitoring

Each PwC firm is responsible for monitoring the effectiveness of its quality control systems.

This includes performing reviews at the management level of the PwC firm’s systems and procedures, and sample reviews at the individual engagement level, including the approval and conduct of non-audit services.

These reviews include a focus on independence and application of required policies and processes.

PwC monitors each firm’s compliance with professional standards and policies, including those relating to independence, through visits to PwC firms. The monitoring programme is based on professional standards relating to quality control, including ISQC1, PCAOB Quality Control Standards and other applicable professional standards.

Any departure from independence requirements in the PwC independence policies and/or external regulations is evaluated. PwC firms follow the relevant procedural steps set out in the IESBA Code of Ethics and/or that issued by other regulatory authorities, which involves discussion with those charged with governance of the client regarding the nature of the breach, the impact on objectivity and whether steps can be taken to mitigate any potential effects.

PwC firms also follow applicable local requirements relating to the reporting of independence matters. Disciplinary measures may follow.

 

Acquisitions

PwC has established protocols and processes that are followed for any proposed acquisition by a PwC firm to ensure that any independence issues are identified and addressed.

 

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 one of the most important measures in assessing a partner’s contribution.

 

Continuing education

The PwC approach to Assurance learning and education (L&E) is to provide access to a formal curriculum of technical courses needed to prepare staff and partners for delivery of high quality assurance services. In some cases, PwC member firms may supplement this curriculum to address additional local training needs.

PwC member firms are committed to delivering quality assurance services around the world. To maximise consistency in the network, the formal curriculum provides access to training material covering: the PwC audit approach and tools, updates on auditing standards and their implications, and areas of audit risk and areas of focus for improved quality.

This formal learning is delivered using a blend of delivery approaches, which include remote access, classroom learning and on-the-job support. The curriculum supports PwC’s primary training objective of audit quality, while providing practitioners with the opportunity to sharpen their professional judgement, scepticism, technical and professional skills.

The formal training is available to the Network in multiple modules that allow PwC member firms to select when they will deliver different portions of the training based on local needs. The conversion to modular content along with other innovative learning approaches have led to formal recognition from the broader learning community. In 2016, PwC's Learning and Education was recognised by the Corporate Learning Network (CLN)[1] with the 2016 International 'Corporate University Best-in-Class' (CUBIC) Award, and in both 2017 and 2018, PwC’s Learning and Education won a Brandon Hall Group silver award for excellence in the "Best Strategy for a Corporate Learning University" © 2017, 2018 Brandon Hall Group, Inc.

While our classroom materials have a variety of designs and formats that deliver the learning experience, all follow consistent principles:

  • Focus on practical application
  • Simulate on the job experiences
  • Make it real; and
  • Make use of technology in the classroom where appropriate

Our remote access materials also have a variety of designs and formats that deliver the learning experience, including the following:

  • ELearns that allow participants to work at their own pace, access learning when needed and provide feedback. Some examples include a simulated on-the-job experience in an immersive solution; use of gamification; and individualised, real-time feedback and coaching based on choices made by the learner during the eLearn.
  • Microlearning and performance support that is accessible at time of need and in small easy-to-absorb videos that range from short lessons on how to use tools, to on-the-job-support to reinforce concepts learning in formal training.

In 2018, PwC’s Learning and Education won a Brandon Hall Group silver award for excellence in the "Best Use of Performance Support" © 2018 Brandon Hall Group, Inc.

[1] The CLN is the leading online resource and event hub for the global training and learning community. The CUBIC Awards are the most prestigious independent awards for training, learning and organisational development professionals worldwide, celebrating the most innovative, creative and forward-thinking learning organisations.

 

Legal structure, ownership, network arrangements and leadership

 

Network arrangements and member firms

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

Network Leadership Team

The Network Leadership Team (NLT) sets the overall strategy for the PwC network and the standards to which PwC firms agree to adhere. The NLT is made up of the Chairman of the PwC network; the senior partners of the US, the UK and China member firms; and a fifth member appointed by the Global Board, currently the chairman of PwC Europe. The Chairman of the PwC network and the fifth member may serve on the NLT for a maximum of two terms of four years each in their respective capacities. The terms of the other NLT members are limited by the arrangements in their respective firms. The NLT typically meets biweekly and on further occasions as required.

Strategy Council

The Strategy Council, which is made up of senior partners of the largest PwC firms and regions, agrees on the strategic direction of the network and facilitates alignment for the execution of strategy. The Strategy Council meets on average four times a year.

Global Leadership Team

The Global Leadership Team is appointed by, and reports to, the Network Leadership Team and the Chairman of the PwC network. Its members are responsible for leading teams drawn from network firms to coordinate PwC's activities across all areas of the business. The GLT typically meets monthly and on further occasions as needed.

Global Board

The Board, which consists of 18 elected members, is responsible for the governance of PwCIL, oversight of the Network Leadership Team and approval of network standards.

The Board does not have an external role outside PwC. Board members are elected every four years by partners exercising their votes through their member firms. The current Board, with members from 13 countries, took up office in April 2017.

Board members may serve a maximum of two terms of four years each. During FY18, the Board met 12 times either in person or by conference call.


Transparency

To read transparency reports for certain PwC network member firms click here.

Contact us

Mike Davies
Director, Global Communications, PwC United Kingdom
Tel: +44 7803 974136
Email

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