A resource and overview of PwC’s personal independence requirements applicable to PwC partners, employees, third-party contractors and their immediate family members.
Personal independence at PwC
What is independence?
Independence means acting objectively and impartially when serving our audit clients by making decisions without outside influence or bias.
- Partners, employees, third-party contractors and their immediate family members should be free from any personal, financial or business relationships that could impair, or be perceived as impairing, the objectivity of the services we provide to our audit clients and their affiliates.
- Individuals should avoid any actual or perceived conflicts arising from their personal, financial, or employment relationships with our audit clients.
- Why do we maintain independence?
- Who has to maintain independence?
- Who is an immediate family member?
Why do we maintain independence?
- Independence is foundational as it relates to public trust in our firm’s audit reports
- PwC is expected by our clients and required by our regulators to maintain our independence, in fact and appearance.
- Individuals must act objectively and impartially when serving our clients by making decisions without outside influence or bias.
Who has to maintain independence?
PwC partners, certain employees and third-party contractors — along with their immediate family members.
Who is an immediate family member?
- A spouse - is a husband or wife, either by marriage or under common law. For SEC restricted entities, independence is still required of a spouse (whether or not estranged) if the professional employee and the spouse are not legally separated under a decree of divorce or separate maintenance.
- A spouse equivalent - is determined by you and is someone who you live with and consider your relationship to be similar to that of a spouse.
The following factors impact whether someone is your spouse equivalent:Having a committed relationship that is ongoing and expected to continue indefinitely similar to that of a married couple, but having either chosen not to marry or unable to legally marry
Co-owning the home in which you live together
Living together and having children together
Living together and being engaged to be married
- A dependent - is any person (whether or not related) who received more than half of their support during the most recent calendar year from you and/or your spouse or spouse equivalent, where applicable.
How can I learn more about personal independence at PwC?
Listen to the Personal independence for PwC family members podcast to learn more about your personal independence responsibilities and how to get help.
What is a financial arrangement and when is it permissible?
A financial arrangement is any of the arrangements described below. Permissible financial arrangements are those that are permitted by independence regulations and PwC policy.
Click on the financial arrangements below to learn more:
Investments
Examples of investments are stocks, bonds, mutual funds, money market funds, investment contracts, options such as puts and calls, other investments in a company and certain crypto tokens. Payment cards and wallets with an investment sweep option are also considered investments.
In certain circumstances, there are restrictions on owning investments in a company that is an audit client of PwC.
Checkpoint or the Compliance Resource Center can assess whether a particular investment is permissible (see more below). Once permissibility is determined, investments must be recorded in Checkpoint within five business days of any transaction.
Credit cards
A credit card is a card issued by a bank which enables people to buy items without cash.
It’s important to know the bank issuing the credit card. In certain circumstances, there are restrictions on maintaining a credit card balance below a certain threshold.
Checkpoint or the Compliance Resource Center can assess whether any independence-related requirements apply (see more below).
Insurance policies
Examples are automobile, boat, motorcycle, ATV or any other vehicle covered, homeowner, second home, vacation home, multi-homeowner, title, renter, umbrella, accident, disability term life, whole life, universal life, variable annuity, variable life, unit linked insurance policies (ULIP), fixed annuity policies and policies obtained through PwC’s program with Marsh Home and Auto Insurance Program or AON Mexico.
In certain circumstances, there are restrictions on entering into a new or making changes to an existing insurance policy with a PwC audit client.
Checkpoint or the Compliance Resource Center can assess which insurance policies are permissible (see more below).
Depository accounts
Examples of depository or bank accounts include checking, savings and money market accounts.
In certain circumstances, there are restrictions on using certain bank account features offered by a PwC audit client, such as overdraft protection or having a balance which exceeds Federal Deposit Insurance Corporation (FDIC), or similar insurance limits.
Note: If you’re a covered person to Kraken, NinjaTrader or PayMe by HSBC, including accounts on Kraken exchange, Kraken app, Kraken Pro, Kraken NFT or Kraken Custody, you and your immediate family members are prohibited from holding one of these accounts.
Checkpoint or the Compliance Resource Center can assess whether any independence-related restrictions apply (see more below).
PayPal and Venmo
Certain online accounts, such as PayPal and Venmo (a service of PayPal), provide the opportunity to hold cash on account.
In certain circumstances, there are restrictions on holding an overnight balance with certain online accounts offered by a PwC audit client.
Checkpoint or the Compliance Resource Center can assess whether independence-related requirements apply (see more below).
Loans and mortgages
Examples are home, vacation and investment property mortgages and unsecured lines of credit.
In certain circumstances, there are restrictions on entering into new or making changes to an existing loan or mortgage with a PwC audit client. In addition, timely payments may be required.
Checkpoint or the Compliance Resource Center can assess which lenders are permissible and whether any other independence-related requirements apply (see more below).
Material leases
Any lease (other than automobile leases and leases from individuals) where the sum of the annual lease payments comprise 5% or more of the household’s gross annual income. The most common example is an apartment lease.
In certain circumstances, there are restrictions on entering into or making changes to an existing material lease with a PwC audit client.
Checkpoint or the Compliance Resource Center can assess which lessors are permissible (see more below).
Brokerage and investment accounts
A brokerage or investment account is an account that enables buying and selling of investments usually through a designated broker, financial advisor or automated advisor. These include demat, asset management, security holding and cash management accounts, along with managed accounts and discretionary accounts.
PwC has restrictions on which investment firms PwC partners, employees, third-party contractors and their immediate family members may maintain an account with.
Even if the investment firm is permissible, there may be restrictions on the account features such as automatic investing, money market sweep and margin options.
Checkpoint or the Compliance Resource Center can assess which investment firms are permissible and whether any other independence-related restrictions apply (see more below).
Employee benefit plans
An employee benefit plan is a plan established by a company to provide retirement and savings benefits to its employees. Common plans include 401(k), 403(b), 457(b), pension plans, profit sharing plans, employee stock ownership plans, employee stock purchase plans, individual retirement accounts (IRA) and health savings accounts (HSA).
Any US-based former employee benefit plan of a PwC partner, employee, or their immediate family members must be rolled over to an account with a permissible brokerage firm or into a current employee benefit plan.
Checkpoint or the Compliance Resource Center can assess which brokerage firms and investments are permissible (see more below). Once permissibility is determined, the investments held through the plan must be recorded in Checkpoint within five business days of any transaction.
National-sponsored plans
National-sponsored plans are retirement savings or pension plans offered through a government or organization and managed at a national level, unlike an employee benefit plan provided through an individual employer. Examples include National Pension Scheme (NPS), Employee Provident Fund (EPF) and Private Retirement Scheme (PRS).
College savings plans
A college savings plan is a tax-advantaged investment account used to pay for education-related expenses. These plans include 529 college savings plans, prepaid tuition plans, child education savings accounts and education funds.
Not all college savings plans are permissible.
Checkpoint or the Compliance Resource Center can assess which plans are permissible. Once permissibility is determined, the plan must be recorded in Checkpoint within five business days of investing in the plan.
Trusts, estates and powers of attorney
Trusts, estates and powers of attorney are types of legal agreements where an individual may exercise control over another individual’s financial assets.
If you or your immediate family members have any power of attorney, are a trustee, co-trustee or grantor of any trust, or if you or your immediate family members are an executor or administrator of any estate, any financial relationships over which you or your immediate family members have control must be treated as yours. This also includes irrevocable (non-grantor) trusts where you or an immediate family member donate the trust's assets and an immediate family member is the beneficiary of the trust.
Additionally, this also includes any accounts owned by another person where you or an immediate family member has been granted trading authority over the accounts.
Checkpoint or the Compliance Resource Center can assess whether a particular financial relationship is permissible (see more below).
Other businesses under your control
Control of a business generally exists when an individual or entity owns more than 50% of another entity.
Personal independence requirements apply to any financial relationships related to any business over which you or your immediate family members have control.
Checkpoint or the Compliance Resource Center can assess whether any independence-related restrictions apply (see more below).
What’s the best way to determine the permissibility of a financial arrangement?
It’s critical to confirm financial arrangements are permitted by independence regulations and PwC policy. Permissibility must be determined before entering into a new financial arrangement or making changes to an existing financial arrangement.
There are three options to determine the permissibility of a financial arrangement:
The PwC Compliance Resource Center
The Compliance Resource Center is a dedicated resource helping PwC partners, employees, third-party contractors and their immediate family members maintain personal independence, including assessing the permissibility of a financial arrangement.
The Compliance Resource Center can be contacted by calling:
- 1-877-PwC-HELP (in the US)
- 800-444-0103 (in Mexico)
- +91 0008000404620 (India Acceleration Center employees)
- +86-2160366800 option 4 (Shanghai Acceleration Center employees)
- +63 (02) 7720-6900 (Manila Acceleration Center)
- 1-813-351-6491 (other countries outside the US)
Note: International charges may apply outside these areas.
CRC Hours:
US & Mexico: Monday – Friday 8am – 6pm ET.
All other locations: Monday – Friday 9am until 6pm IST.
Note: All chats close an hour before closing.
PwC partners and their immediate family members have dedicated Partner Outreach support - with multiple ways to get assistance with any personal independence questions.
PwC’s Checkpoint tool
This proprietary tool informs PwC partners and employees (and their immediate family members and financial advisors) which financial arrangements are permissible and alerts them if a financial arrangement becomes impermissible.
- PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.
Be aware that Checkpoint may indicate a permitted status because it is a PwC audit client, including its affiliates. Keep in mind, even if there is a green (Permitted) checkmark, PwC partners, employees, third party contractors and their immediate family members can’t buy or sell investments in any entity if they’re in possession of material, non-public information and must be aware of certain prohibitions on trading time period related to non-audit clients.
PwC partners and employees
PwC partners and employees can pre-clear financial arrangements using Checkpoint.
- PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.
