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Upholding our quality and ethics

We provide a detailed insight into our approach to how we govern ourselves and address risk in our 2019 Annual report, together with our view on the future of assurance and a report from our Public Interest Body in our 2019 Transparency Report. Additionally, we report our performance against a number of externally assured metrics around quality and ethics in our sustainability scorecard.

Our approach

As a professional services firm, much of our success depends on our ability to build and sustain trust. So, we've created an ethical framework that incorporates the applicable standards, laws and regulations for our business. However, we've also chosen to go beyond these requirements and we've captured how we do this in our Code of Conduct which covers all of our work, and we have a supplementary tax code of conduct for our tax practice. The tone for our ethical approach is set right at the top of the firm, with the Management Board promoting a culture, policies and expectations that support and encourage all of our people to ‘do the right thing’, especially when they have to make difficult decisions.

We embed the need for quality throughout our business, with detailed procedures and policies in place which address ethics, human resources and the way we engage with our clients, for example. Measuring our progress also helps us keep us on track.

We also expect our suppliers to conform to similar ethical standards and, where relevant, to have systems and practices in place to ensure the prevention of:

  • Money laundering
  • Insider trading
  • Conflicts of interest
  • Fraud, bribery and corruption
  • Unauthorised access to personal and business information

Opportunities and risks

It's vital that everyone who comes into contact with us can trust us. That's why we strongly emphasise ethics and compliance. We aim to do business with confidence, integrity and care.

Trust with our clients, suppliers, our people and our other stakeholders means we can commit more quickly to decisions, actions, and investments. It also allows us to attract and retain talented employees.

Programmes and systems

We have a strong set of internal programmes and systems in place to uphold our values and make sure we all adhere to our Code. These include:

Ethics training

All of our partners, staff and contractors undertake regular mandatory training to help them understand our ethical requirements, and we take a zero tolerance approach to non-completion of this training. We make it clear that we expect our people to embrace both the spirit and the letter of these requirements. Given the importance of ethics to our continued success, we measure and report our people’s perception of how ingrained ethical behaviour and culture is in the business through our ‘youmatter’ people survey. In 2019, 76% of our people agreed or strongly agreed with the statement that “At PwC I feel comfortable discussing or reporting ethical issues and concerns without fear of negative consequences.” For transparency, we also report on the number of dismissals for misconduct. In 2019, there were 16 such dismissals.

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We have policies, procedures and practices in place to make sure we maintain the necessary personal and firm independence from our audit clients, and which cover non-audit services, fee arrangements and business relationships. These form part of the mandatory training provided to all partners and staff. Deviations from policies and procedures, where they breach external rules, are reported to the Management Board and the regulator and can result in disciplinary action. We also provide information on breaches of external independence regulations that were reported to the regulator in our sustainability scorecard. In 2019, this figure was 0.27%, as a percentage of full time employees.

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Data security

Confidentiality is vital to our business. Misusing or losing confidential client information or personal data could expose our clients to risk or us to legal proceedings. It could also harm our reputation. All partners and staff receive regular training on their confidentiality obligations.

We operate an Information Security Management System that complies with the requirements of ISO/IEC 27001:2013 for all client data that comes under our control or ownership by virtue of a contract for services between PricewaterhouseCoopers LLP and a client.

Our information security policies and procedures aim to make sure that:

  • information is protected from internal and external threats
  • confidentiality, availability and integrity of information is maintained
  • statutory, regulatory and contractual obligations are met
  • access to information is granted only for justified business needs

Our ISO 27001 certification is subject to ongoing external assessments at all of our UK sites. As an indicator of our commitment to continual improvement in this area, we report the number of major and minor ‘nonconformities’ to the standard that our external assessorsidentify. There have been no nonconformities in recent years.

For more information on the UK and international standards to which our management systems are certified see our standards page.

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Client and engagement acceptance

We have rigorous procedures for not only accepting new clients but also continuing to work with existing clients as well as approving specific engagements. They help us to understand whether risks related to an existing or potential client are manageable, and whether we should do business with particular businesses or people.

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Our Code of Conduct makes it clear that it's unacceptable for our people to solicit, accept, offer, promise or pay bribes. Policies, training and procedures designed to prevent bribery are in place.

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Our whistle-blowing helpline (+44 (0) 20 721 25233) is called Speak Up, and is available to any partner or employee who comes across bad business conduct or unethical behaviour that can't be resolved locally or for which the normal consultation process isn't suitable. Anyone raising a genuine concern which is in the public interest will be protected from victimisation. Third parties (including clients) can also telephone the Speak Up helpline.

For more information on our ethical requirements, including our Code of Conduct and independence procedures, take a look at our Transparency Report.

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Contact us

Nicola Shield

Nicola Shield

Ethics Partner

Tel: +44 (0)7931 388648

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