www.pwc.

com/ethics

Doing the
right thing
the PwC way
Code of conduct

Acting professionally. Doing business with integrity. Upholding our

clients reputations as well as our own. Treating people and the
environment with respect. Acting in a socially responsible manner.
Working together and thinking about the way we work. Considering
the ethical dimensions of our actions. This is the PwC Experience,
expressed in our Code of conduct.

How we present ourselves

We invest in relationships
Identity

Experience

What were
good at
We enhance
value

What we
stand for
Capabilities
Culture
How we behave
We put ourselves in
each others shoes

What its like to

work with us
We share and
collaborate

Putting our values in action

Our valuesexcellence, teamwork
and leadership

Achieve excellence
Delivering what we promise
and adding value beyond what
is expected. We achieve
excellence through innovation,
learning and agility.
Develop teamwork
The best solutions come
from working together with
colleagues and clients.
Effective teamwork requires
relationships, respect and
sharing.

Excellence

Teamwork

Leadership

Inspire leadership
Leading with clients, leading
with people and thought
leadership. Leadership
demands courage, vision
and integrity.

Code of conduct
PwC1 is one of the worlds pre-eminent
professional services organisations. As
professional advisers we help our clients solve
complex business problems and aim to enhance
their ability to build value, manage risk and
improve performance.
As advisers we play a significant role in the
operation of the worlds capital markets. We
take pride in the fact that our services add value
by helping to improve transparency, trust and
consistency of business processes. In order to
succeed, we must grow and develop, both as
individuals and as a business. Our core values of
Excellence, Teamwork and Leadership help us to
achieve this growth.
We conduct our business within the framework
of applicable professional standards, laws, and
regulations together with PwC policies and
standards. However, we also acknowledge that
these standards, laws, regulations and policies
do not govern all types of behaviour. As a result,
we also have a Code of conduct for all PwC
people and firms. This Code is based on our
values and it takes them to the next level
demonstrating our values in action and
contributing to the PwC Experience. The Code
also provides a frame of reference for PwC firms
to establish more specific supplements to
address territorial issues.
4

Each of us at PwC has an obligation to know and understand not

only the guidelines contained in the Code, but also the values on
which they are based. Knowing and understanding are not
enough. We also have an obligation to comply with the letter and
spirit of this Code and to help others do the same. As individuals
we are encouraged to raise any issues and concerns through
appropriate channels.
While the Code provides a broad range of guidance about the
standards of integrity and business conduct, no code can address
every situation that individuals are likely to encounter. As a
result, this Code is not a substitute for our responsibility and
accountability to exercise good judgment and obtain guidance on
proper business conduct. We are encouraged to seek additional
guidance and support from those designated as responsible for
business conduct matters. The strength in our organisation is the
strength in our collective knowledge and the sharing of that
knowledge and experience.

1
PwC (www.pwc.com) provides industry-focused assurance, tax and advisory
services to build public trust and enhance value for its clients and their
stakeholders. More than 161,000 people in 154 countries across our network
share their thinking, experience and solutions to develop fresh perspectives
and practical advice.

In this publication the terms PwC, our and we refers to the network of
member firms of PricewaterhouseCoopers International Limited, each of
which is a separate and independent legal entity.
5

Upholding the PwC name

Our clients and colleagues trust PwC based on

our professional competence and integrity
qualities that underpin our reputation. We
uphold that reputation.
We seek to serve only those clients whom we
are competent to serve, who value our service
and who meet appropriate standards of
legitimacy and integrity.
When speaking in a forum in which audiences
would reasonably expect that we are speaking
as a representative of PwC, we generally state
only PwCs view and not our own.
We use all assets belonging to PwC and to our
clients, including tangible, intellectual and
electronic assets, in a manner both responsible
and appropriate to the business and only for
legal and authorised purposes.

Behaving professionally

We deliver professional services in accordance

with PwC policies and relevant technical and
professional standards.
We offer only those services we can deliver
and strive to deliver no less than our
commitments.
We compete vigorously, engaging only in
practices that are legal and ethical.
We meet our contractual obligations, and
report and charge honestly for our services.
We respect the confidentiality and privacy of
our clients, our people and others with whom
we do business. We comply with applicable
laws, regulations and professional standards in
order to maintain the appropriate degree of
confidentiality and privacy.
We aim to avoid conflicts of interest. Where
potential conflicts are identified and we believe
that the respective parties interests can be
properly safeguarded by the implementation
of appropriate procedures, we will implement
such procedures.

We treasure our independence of mind. We

protect our clients and other stakeholders trust
by adhering to our regulatory and professional
standards, which are designed to enable us to
achieve the objectivity necessary in our work. In
doing so, we strive to ensure our independence
is not compromised or perceived to be
compromised. We address circumstances that
impair or could appear to impair our objectivity.
When faced with difficult issues or issues that
place PwC at risk, we consult appropriate PwC
individuals before taking action. We follow our
applicable technical and administrative
consultation requirements.
It is unacceptable for us to solicit, accept,
offer, promise or pay bribes.

Respecting others

We treat our colleagues, clients and others

with whom we do business with respect,
dignity, fairness and courtesy.
We take pride in the diversity of our workforce
and view it as a competitive advantage to be
nurtured and expanded.
We are committed to maintaining a work
environment that is free from discrimination,
harassment and retaliation.
We try to balance work and private life, and
help others to do the same.
We invest in the ongoing enhancement of our
skills and abilities.
We provide a safe working environment for
our people.

10

11

Corporate citizenship

We express support for fundamental human

rights and avoid participating in business
activities that abuse human rights.
We act in a socially responsible manner,
within the laws, customs and traditions of the
countries in which we operate, and contribute
in a responsible manner to the development
of communities.
We aspire to act in a manner that minimises
the detrimental environmental impacts of
our business operations.
We encourage the support of charitable,
educational and community service activities.
We are committed to supporting international
and local efforts to eliminate corruption and
financial crime.

12

13

Our responsibilities

The PwC Code of conduct defines how we should

behave and conduct business in a wide range of
settings and situations. The attached Framework
for ethical decision making supplements the Code
and will help us resolve issues.
It is the responsibility of each of us to follow the
Code of conduct and PwC policies consistently
and appropriately and help others to do so.
When non-compliance with our Code of
conduct is reported or otherwise suspected,
steps will be taken to investigate and, if
appropriate, remedy the situation.
We are encouraged to report and express our
concerns and must do so fairly, honestly and
respectfully. PwC is committed to protecting
individuals against retaliation. People in the
reporting line are responsible for addressing
issues that are brought to their attention.

14

Those who violate the Code or PwC policies and

procedures will be subject to disciplinary action,
up to and including dismissal. Disciplinary
measures will also apply to anyone who directs
or approves infractions or has knowledge of them
and does not promptly move to correct them.
We are committed to the spirit of cooperation
among PwC firms and the pursuit of common
business objectives. When faced with business
conduct questions or concerns on international
assignments, the established policies of the host
country should always be followed. If we are not
satisfied with the resolution after following the
prescribed process within the host firm, we should
seek resolution in our home country. The issue
will then be addressed amongst the respective
leaderships within the countries involved.

15

Framework for ethical

decision making

As a guide in deciding on a course of action, follow

these steps and ask yourself these questions:
Recognise the event, decision or issue. Are
you being asked to do something that you think
might be wrong? Are you aware of potentially
illegal or unethical conduct on the part of others
at PwC or a client? Are you trying to make a
decision and are you unsure about the ethical
course of action?
Think before you act. Summarise and clarify
your issue. Ask yourself, why the dilemma?
Consider the options and consequences.
Consider who may be affected. Consult others.
Decide on a course of action. Determine your
responsibility. Review all relevant facts and
information. Refer to applicable PwC policies or
professional standards. Assess the risks and how
you could reduce them. Contemplate the best
course of action. Consult others.

16

Test your decision. Review the ethics

questions to consider. Apply PwCs values to
your decision. Make sure you have considered
PwC policies, laws and professional standards.
Consult othersenlist their opinion of your
planned action.
Proceed with confidence. Communicate
decision and rationale to stakeholders. Reflect
upon what was learned. Share your success
stories with others.

17

Summary of ethics
questions to consider

1.
2.
3.
4.
5.
6.
7.
8.
9.
10.

Is it against PwC or professional standards?

Does it feel right?
Is it legal?
Will it reflect negatively on you or PwC?
Who else could be affected by this (others in
PwC, clients, you, etc.)?
Would you be embarrassed if others knew you
took this course of action?
Is there an alternative action that does not pose
an ethical conflict?
How would it look in the newspapers?
What would a reasonable person think?
Can you sleep at night?

For further information, please visit:

www.pwc.com/ethics

18

19

www.pwc.com
2011 PwC. All rights reserved. Not for further distribution without the permission of PwC.
PwC refers to the network of member firms of PricewaterhouseCoopers International Limited
(PwCIL), or, as the context requires, individual member firms of the PwC network. Each member
firm is a separate legal entity and does not act as agent of PwCIL or any other member firm.
PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or
omissions of any of its member firms nor can it control the exercise of their professional judgment
or bind them in any way. No member firm is responsible or liable for the acts or omissions of any
other member firm nor can it control the exercise of another member firms professional judgment
or bind another member firm or PwCIL in any way. MW-11-0135