www.pwc.

com/codeofconduct

Living our Purpose

and Values
PwC’s Code of Conduct
April 2021
 Table of contents

i/ii
Message from our Global Chairman
Message from our Global Chief Ethics & 12
Compliance Officer Build trust in our communities

1 16
Living our Purpose and values Build trust in how we use information

2 20
The Code in context RADAR: A framework for deciding the right thing to do

3 23
We listen and take action
Speak up The Code of Conduct, and the PwC network of firms

4 24
Build trust in how we do business Index

8 25
Build trust with each other Contact information

Living our Purpose and Values—PwC’s Code of Conduct

 Message from our Global Chairman

Dear Colleagues:
PwC is recognised as a global leader in professional services, working with many of the world’s
most well-known organisations in countries around the world. As the opportunities and challenges
we all see get bigger and more complex, we continue to adapt. But as we evolve as a business, what
must drive everything we do is our collective and individual commitment to the PwC Purpose and
our values—the foundations of our network.

With over 200,000 of us working across more than 150 countries, we each have a role to play in
making a real difference for our clients, the capital markets, our teams, our communities, and our
broader stakeholders. We have a responsibility to understand why we do the things we do through
our Purpose, what we focus on through our strategy, and how we work together through our values,
behaviours, and conduct.
Bob Moritz
Chairman, PricewaterhouseCoopers Purpose defines who a business is and why it exists, acting as a vital guidepost and benchmark
International Limited to every decision. While a business’ purpose may remain consistent, a growing challenge is that
the expectations society places on all of us continue to change… and changing fast thanks to the
big trends we all see and experience like demographic shifts, technological advances, flow of
information instantaneously and many others. From environmental footprints to social impacts to
investor demands and everything in between, businesses are expected to exhibit responsive and
responsible behaviour in more areas and be accountable to an ever wider array of stakeholders.
PwC Purpose:
The trust that our clients, communities and our people place in PwC, and our high standards of
To build trust in society and ethical behaviour, are fundamental to everything we do. As we go about our work it’s important we
solve important problems have a frame of reference for the decisions we make every day. Our Code of Conduct (Code) can
guide us, no matter where we are or what we do. It’s how we do business.

The Code reinforces the importance of conducting business within the framework of professional
standards, laws, and regulations, together with our own policies, values, and standards, even as we
work across borders. It outlines the values and behaviours that define how we do business. It holds
us accountable to be open-minded and responsive and to give our best.
What we achieve as PwC is entirely dependent on how we all individually put our Purpose and
our values at the centre of everything we do—every day, in every action. So let’s work together to
build trust and solve important problems. Let’s encourage collaboration, cultivate curiosity and
innovation, act with integrity and foster a sense of care, always.

Living our Purpose and Values—PwC’s Code of Conduct i

 Message from the Global Chief
Ethics & Compliance Officer

Dear PwC teams:

The Code of Conduct is based on the PwC Purpose and a core set of shared values, and
sets out a common framework around how we are expected to behave and to do the right
thing. Knowing, understanding, and living the Code, is a fundamental part of who we are
as PwC professionals, and what we stand for. Whether we are working with PwC people
or others, we depend on each other to be mindful of our ethical responsibilities.

Our Code of Conduct reflects the significant changes in our world, the very nature of our work
and how we do business today, as well as our need as trusted professionals to understand how
to continue to behave ethically in the face of all of these changes. The Code is one of many
Laurie Endsley tools we have as professionals to help guide our behaviour, and is intended to be a framework,
Chief Ethics & Compliance Officer, not a rulebook. It cannot, and does not, cover every situation you might encounter but rather
PricewaterhouseCoopers International Limited seeks to embed our values into our day to day behaviours and ethical decision making.

We are all an important part of this effort. Each of us has a part to play in living and
upholding the behaviours outlined in this Code. But, we do not go it alone. We are all in
this together. We support each other. We rely on each other to understand and adhere
to all of these professional behaviours and standards, and apply them consistently. We
collaborate on every level, and we help each other build skills in doing the right thing.

If we come across a situation that is inconsistent with our Code, we speak up. We value the
courage it takes to raise concerns. Remember, investigations into allegations of misconduct are
handled discretely and with sensitivity and we do not tolerate retaliation. When in doubt or
facing a dilemma, we ask for help. There are local and network resources available to help us.

I look forward to working with all of you to maintain and foster PwC’s robust ethical culture.

Thank you.

Living our Purpose and Values—PwC’s Code of Conduct ii

 olicies • Standar
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Living our Purpose and values

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The PwC culture thrives supported by a framework of

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These help guide our behaviours and build trust:

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When working with our clients and our colleagues to build trust in society and solve important problems, we...

•  peak up for what is

S •  tay informed and
S •  ake the effort to
M •  ollaborate and
C •  are to challenge
D
right, especially when ask questions about understand every share relationships, the status quo and
it feels difficult the future of the individual and what ideas and knowledge try new things
•  xpect and deliver the
E world we live in matters to them beyond boundaries • Innovate, test and
highest quality outcomes •  reate impact with
C •  ecognise the value
R •  eek and integrate
S learn from failure
•  ake decisions and
M our colleagues, our that each person a diverse range •  ave an open mind
H
act as if our personal clients and society contributes of perspectives, to the possibilities
reputations were at stake through our actions •  upport others to
S people and ideas in every idea
•  espond with agility
R grow and work in •  ive and ask for
G
to the ever changing the way that brings feedback to improve
environment in out their best ourselves and others
which we operate

Living our Purpose and Values—PwC’s Code of Conduct 1

 The Code in context
Our Purpose and values are the foundation of our success. We exist to
build trust and solve important problems, and our values help us deliver
on that Purpose.

This Code underpins our ability to behave in a manner consistent with

our values.

Our Code is not meant to provide specific guidance on every situation

where we might need to answer the question, “What is the right thing
to do?” Instead, it is principle-based guidance that helps us think about
difficult questions, promotes consultation, and encourages us to speak
up if we have concerns. On page 20 of this Code, you will find details
on RADAR (Recognise, Assess, Decide, Agree, Report), which is our
framework for helping us decide the right thing to do.

This Code describes a common set of expectations for our conduct, a key
element of which is that we abide by applicable laws and regulations.
To the extent any local law or regulation is more restrictive than this
Code, local law or regulation governs. Network and local policies and
supplemental guidance complement the principles embodied in this Code
and the PwC Network Risk Management Policies.

The Organisation for Economic Co-operation and Development (OECD)

provides guidance, including the OECD Guidelines for Multinational
Enterprises (the OECD Guidelines), by way of non-binding principles
and standards for responsible business conduct when operating
globally. The OECD Guidelines provide a valuable framework for
setting applicable compliance requirements and standards. Although
the PwC network consists of firms that are separate legal entities which
do not form a multinational corporation or enterprise, PwC’s network
standards and policies are informed by and meet the goals and objectives
of the OECD Guidelines.

This Code applies to all of us. When we say “we” “our” or “us” we are
referring to all of us at PwC, individual partners/principals and staff, as
well as the individual firms that together form the PwC network.

Living our Purpose and Values—PwC’s Code of Conduct 2

Speak up
Speaking up is crucial to our culture and our long term results—it is a We protect against retaliation. In being true to the values of integrity
living example of our values. Speaking up when something doesn’t seem and care—if you report a concern, it will be handled with appropriate
right demonstrates our integrity and that we have the courage to do the confidentiality and discussed with others only as needed or advisable
right thing. Speaking up helps to prevent mistakes and misconduct and under the circumstances. Exercising professional scepticism, applying
foster innovation. Speaking up shows that we care about each other and common sense, and knowing and applying the Code as well as the
our business. And speaking up to get things right or keep them on track local supplementary guidance, will help each of us know when to
helps us live up to our commitment to deliver high quality outcomes. speak up through whichever channel we are most comfortable.
As well as the resources listed here, we can raise concerns using the PwC
Something doesn’t seem right? Facing a dilemma?
Ethics Helpline. Each PwC firm has its own Ethics Helpline or you may
Have a question that leads to more difficult questions? report to the Global Helpline if you prefer.
Need advice?
Consult. Pick up the phone. Send an email. Set up a meeting. Speak up. Speak up. It’s the right thing to do.
Each of us, no matter what our level or role, is empowered to speak These are the moments that matter.
up when dealing with behaviour or facing a situation that doesn’t
seem right. Each of us has a responsibility to report and express
our concerns, and to do so fairly, honestly, and professionally.
PwC is committed to protecting our people against
Do not ignore it. Do not stay silent. retaliation. Retaliation is serious misconduct that
will not be tolerated, and any PwC professional
Collaboration means we consult with our colleagues in matters large
(including partners/principals or staff) who takes
and small, and we know that our concerns are heard and addressed
retaliatory action will be held accountable.
in an open and professional manner, including that an investigation
will take place when warranted. We consult with our supervisors,
coaches, partners/principals, ethics teams, Risk and Quality teams, Q. What is retaliation?
Office of the General Counsel, Human Capital representatives, or A. Retaliation can be any form of reprisal, direct or subtle,
others at PwC, particularly those in reporting lines. These people are for reporting in good faith actual or suspected issues.
responsible for addressing or escalating as necessary the issues brought
to their attention. We raise issues using formal and informal methods
as appropriate: in person, over the phone, and/or electronically. We consult with our:
• Supervisors • Risk and Quality teams
• Coaches • Office of the General Counsel
• Partners/Principals • Human Capital
• Ethics teams representatives
• Others at PwC

Living our Purpose and Values—PwC’s Code of Conduct 3

Build trust in how we do business

Whatever our professional

background is, we behave
with integrity and adhere
to, and are guided by, the
applicable professional
standards (e.g., such
as those established by
the International Ethics
Standards Board for
Accountants (IESBA)).

Living our Purpose and Values—PwC’s Code of Conduct 4

 Build trust in how we do business

We are willing to walk away from

engagements and clients if our
The quality and impact of our work is critical Our business judgment is free from bias, independence, integrity, objectivity,
to who we are as PwC professionals, and as a conflicts of interest or undue influence
network of firms. Our sustained performance is of others. We follow processes and
or professionalism could be called
part of how we create and build trust with our procedures to identify and address any into question if we continued.
clients, in each other, and in our communities. actual or potential conflicts of interests.
We serve only clients that we’re competent to We recognise that independence, including
serve, who value our service, and who meet the appearance of independence, is at the
appropriate standards of legitimacy and integrity. heart of objectivity. We proactively avoid
We provide only services we are professionally and address circumstances that create,
capable of delivering. We collaborate to bring or might be seen to create, threats to our
the necessary skills and innovation to our independence of assurance clients.
work. We deliver on our commitments.

Our reputation is defined by trust, integrity, and What if?

achieving high quality sustainable value. Our
continued success means upholding professional I’m new to PwC. I know we have The rules on investments are
standards, adhering to applicable laws and independence requirements, which complex, so it is always good to
regulations, and fulfilling ethical obligations I understand. But can you just double check. Contact your local
remind me how I can check if I am independence specialist or help
while delivering high quality, innovative work.
allowed to invest in a company? desk and they will guide you.

Conflicts can take many forms. Consult when the following kinds of
situations arise:
• There are PwC or personal interests, which • When we are asked to do work for one client
could impact, or could be perceived as which may be seen to be against the interests
impacting, our objectivity in doing what of another client.
is best for our client(s). These situations do not necessarily mean that
• When PwC and a client are on opposite we can’t do the work, but that we need to
sides of the same matter. consider how to manage the potential conflict
or any perceived client sensitivities.

Living our Purpose and Values—PwC’s Code of Conduct 5

 Build trust in how we do business

We demonstrate our integrity by:

Negotiating and securing contracts What if ?
lawfully and honourably with our clients,
My supervisor has implied that I I attended a meeting with a
suppliers, and other parties. We meet
should reduce the number of partner and several competitors to
our contractual obligations, and adhere
hours I’ve recorded on my discuss technical accounting
to the agreed terms and conditions.
timesheet. I know I’ve been issues. At the gathering
Being transparent in disclosing the basis working more than the budgeted hours but afterwards, a peer (from a
on which we charge for our services. We I feel like I’ve worked as efficiently as competitor) mentioned that he is excited
record our time and expenses accurately. possible. What should I do? about a new pricing structure he and his
group are putting in place. He suspects all
Competing fairly. We do not enter into the other firms will adopt the same
any agreements with our competitors, You must record your hours
structure and offered to share it with me in
formally or informally, to unlawfully accurately as incurred. You should
the interests of “being competitive” if I
restrict competition, set prices, or allocate not reduce or inflate hours, and you
should not sacrifice quality just to get would share our team’s pricing structure
clients, markets, people, or services. with him. What should I do?
the job done in the allotted hours.
Respecting our competitors’ confidential You should immediately discuss your concern You should make it clear you do not
information. We collect information with your supervisor. If your supervisor want to receive it, and will not share
about competitors only if it’s available ignores your concern, you should discuss with any such information. Immediately
publicly, or doing so doesn’t breach other appropriate resources. Remember that report the matter to OGC.
legal or contractual obligations. RADAR is a resource as well. Exchanging pricing information in
this manner is prohibited.

Living our Purpose and Values—PwC’s Code of Conduct 6

 Build trust in how we do business

“Facilitation payments” are payments of small value provided (in cash or kind)
to government officials to perform routine functions that they are otherwise
We demonstrate our integrity by: obligated to perform (such as to expedite obtaining permits, licenses, visas, mail,
Never engaging in bribery or corrupt practices.
or utilities). Facilitation payments do not include legitimate administrative fees
This is vital to maintaining the trust of our and legitimate payments for fast track services that are paid to an organisation
colleagues, clients, and others we work with. (not to an individual), and where a receipt may be issued on request.
We do not solicit, accept, offer, promise, or
pay bribes, including facilitation payments—
whether directly or through a third party.
What if ?
Knowing the identity of our clients and others
with whom we do business, and adhering to In my culture, it is typical to give It depends on a number of factors.
applicable standards on anti-money laundering. and receive holiday gifts from Local customs/laws/regulations and
Where we suspect criminal behaviour, we take clients. But the Code indicates PwC policies, and the policies of our
appropriate action. We do not conduct any there are circumstances where the clients, vary. We need to be
activities in breach of applicable economic gifts may be considered inappropriate. particularly careful when dealing
sanctions or undertake services which assist What should I do? with public sector, including government,
clients in breaching applicable sanctions laws. clients. Check your firm’s supplemental
guidance and policy for specific restrictions, or
you should consult with appropriate resources,
such as HR or your local OGC. Remember that
RADAR is a resource as well.

A bribe is not only payment or receipt of cash. A bribe can be

anything of value and can take many other forms, including:
• Consultancy fees and commissions to parties not actually performing services;
• Payments in-kind including any non-cash items of value such as travel, hospitality,
entertainment, employment opportunities, and gifts;
• Employment of family members of government officials outside the normal hiring
process; and
• Sponsorships/donations.

Living our Purpose and Values—PwC’s Code of Conduct 7

Build trust with each other

There is strength and value

in diversity of thought
and experience. Diversity
of perspectives is critical
to innovation. We listen
to each other, we succeed
when we collaborate,
engage in dialogue, and respectfully
debate issues. Pulling together our
ideas and collective knowledge is
fundamental to our ability to innovate
and ultimately to our success.
Agnès Hussherr
Global Human Capital Leader

Living our Purpose and Values—PwC’s Code of Conduct 8

 Build trust with each other

We encourage collaboration across territories

and around the PwC network. Trust is key to this What if ?
collaboration, as it helps us to more effectively
work with our colleagues and serve clients. Trust After work, I attended a gathering Whenever I ask my manager a
begins with each of us treating each other with with the rest of my team. One of question, she publicly mocks me
care, courtesy, dignity, fairness, and respect. my managers made several and questions my qualifications.
unwelcome advances towards me. What do I do?
We take appropriate measures to protect What should I do?
the safety of PwC people. We provide a safe This behaviour may be considered
Unwelcome advances are never bullying, and at a minimum is
working environment free of abusive, violent,
acceptable. If you are comfortable disrespectful and inconsistent with
threatening or other disruptive behaviour.
doing so, professionally and our Code. Speak up. You can talk to
We do not tolerate harassment, respectfully address the situation your Human Capital contact, ethics
discrimination, bullying, or disrespectful with the manager, and know that teams, or other resources you’re comfortable
behaviour.* These behaviours undermine going forward, you can always do so in the with. RADAR can help guide your thinking.
the integrity of our relationships. moment. You should also speak up and
consult with the appropriate resources, such
We respect and encourage open dialogue, to as Human Capital, or the ethics teams so that
create a climate for frank and honest discussions. additional steps may be taken consistent with
established firm processes. Remember that
RADAR is a resource as well.

*This applies whether based on an individual’s race, ethnicity, colour, age,

gender, gender identity or expression, sexual orientation, political beliefs,
citizenship, national origin, language, religion, disability, parental status,
economic/class status, veteran status, or other inappropriate basis.

Living our Purpose and Values—PwC’s Code of Conduct 9

 Build trust with each other

We value the diversity of our workforce as

a competitive advantage that we nurture We speak up for ourselves, and
and expand.
each other, when faced with the
We promote a culture that cares about inappropriate behaviours of
and fosters innovation, professional others, including clients.
growth, career development, workplace
flexibility and work/life balance. What if ?
We invest in our people and their career If you are comfortable doing so,
I was in the lunch room with my
growth by encouraging continual learning, professionally address the situation
colleagues, just having a casual
and by creating opportunities to support with your colleague. If you do not
conversation, and one of them
both near-term development and long-term feel comfortable addressing the
made a comment about another
career progression. Continuously learning, situation yourself, need guidance, or
colleague that I found offensive. How do I
and being open minded, is key to our ability you are concerned that additional steps
handle this situation?
to innovate and solve important problems. should be taken, then you should talk to the
appropriate resources such as your Coach or
HR manager. Don’t forget that RADAR
provides a framework to help in your decision.

• If you experience or witness something that does not feel right, voice
your concerns. Reach out to appropriate resources. It is safe to speak up.

• We protect our people against retaliation for reporting concerns in good

faith. Retaliation is itself a form of serious misconduct that PwC does
not tolerate. Any PwC professional (including partners/principals, or
staff) who takes retaliatory action will be held accountable.

Living our Purpose and Values—PwC’s Code of Conduct 10

 Build trust with each other

wC Professio
At each level and dimension of the PwC Professional,
heP na
expectations on ethical behaviour are defined. T ips Bu
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The most innovative solutions
come from working together with
colleagues and clients. Effective
collaboration enables innovation.

Living our Purpose and Values—PwC’s Code of Conduct 11

Build trust in our communities

Our corporate
responsibility strategy
is tailored to our
specific strengths and
opportunities as a
network of professional
services firms. It’s
also designed to
enable us to apply our
skills in ways that
have impact, deliver
measurable outcomes
and make a true
difference in creating
long-term business
and societal value.

Living our Purpose and Values—PwC’s Code of Conduct 12

 Build trust in our communities

We further our contribution to society by using We respect the limits of our planet and adopt
our skills and experience to help solve important a preventative approach to minimise the
problems, including those related to ethics, environmental impacts of our business. We
integrity, and trust—issues central to fostering a also help our clients to do the same.
sustainable and inclusive global economy.

We support a shift to a more sustainable society

by providing services that transform business and
civil society, contribute to wider development
goals, and reduce environmental impact.

We help solve important social problems in our

communities by contributing our professional
expertise and collaborating with other
organisations to achieve maximum results.

We respect and honour the customs and

traditions of the countries in which we operate.
If these customs and traditions conflict with this
Code, we consult internally on how to adhere to
the Code while being respectful of local culture
and traditions. We aim to gain the trust of our
stakeholders by showing care, openness and
honesty and focusing relentlessly on ethics
and quality.

Living our Purpose and Values—PwC’s Code of Conduct 13

 Build trust in our communities

We participate in the dialogue to help shape

legislation and regulation in a manner that What if ?
upholds the public interest and our Purpose.
I have an opinion about the I am on the professional ethics
We support the rule of law in our interactions political situation(s) in my committee of a professional
with regulators. We work with government country. May I express my accountants’ association, which has
and professional authorities in a respectful personal political affiliations agreed to take a view on a proposed
and forthright manner. Contacts, on behalf or views via social media? standard that differs from PwC’s
of PwC, with government and professional view. May I publicly present the association’s
authorities are generally handled by Yes, however be respectful of
others. Make sure that it is clear view (such as in public hearings)?
designated partners/principals and staff.
you are speaking for yourself and Yes, as long as you clearly indicate
We respond promptly to governmental not for PwC. that those are the views of the
and professional authorities’ requests for committee and not of PwC and,
information, as required by applicable A client has asked me to speak at a when necessary, be prepared to
law and professional obligations. conference which they are explain the difference between the
sponsoring on certain political PwC and association views.
We encourage and support involvement in issues pertaining to them. May I
community activities. We do not represent our accept the speaking engagement?
personal political affiliations or views as those of
Consult with appropriate resources.
PwC, and we comply with applicable reporting
A good place to start is with your
requirements. We avoid using PwC resources (or
Risk and Quality team to determine
creating the appearance that PwC is supporting, whether we are in a position to
endorsing, or opposing any particular political comment.
position or political party/candidate, charity,
product, or specific religion), without approval.

Living our Purpose and Values—PwC’s Code of Conduct 14

 Build trust in our communities

We care about, respect and support

internationally proclaimed human rights. Internationally recognised labour principles
We work to guard against complicity in
include, for example, principles in the
human rights abuses. We comply with
applicable labour and employment laws, UN Global Compact and the aims of the
and draw on internationally recognised International Labour Organisation.
labour principles in how we do business.

We are responsible taxpayers. We manage

all our relevant tax filings, domestic and
foreign, with accuracy, in good faith, and on
time. We only pursue tax planning initiatives
or adopt filing positions which would not
adversely impact the reputation of PwC. We
apply the Global Tax Code of Conduct
to our member firms, and to our partners/
principals and staff, as we apply it to clients.

The global nature of the business world together with the

complexity and competing priorities of national laws, are such that
it is not always clear where lines should be drawn. Accordingly, the
member firms of the PwC network have adopted the Global Tax
Code of Conduct to assist their clients, other stakeholders, and
their respective partners/principals and staff.

Living our Purpose and Values—PwC’s Code of Conduct 15

Build trust in how we use information

Regardless of
whether confidential
information is
received verbally,
on paper, in an
email, or in any
other form, our ability to protect
its confidentiality is critical to
our ability to maintain the trust
of our clients, each other, and
those with whom we do business.

This trust contributes to

collaboration and innovation,
as ideas and information
are more freely shared.

Living our Purpose and Values—PwC’s Code of Conduct 16

 Build trust in how we use information

We respect the privacy and confidentiality

of information of our clients, our people, We all play a role in protecting confidential information entrusted
and others with whom we do business. to us in its various forms.
We protect personal and other confidential 1. We only use approved PwC systems and applications in our work.
information in all forms.
2. We do not inappropriately divulge confidential information,
We collect, store, use, transmit, and dispose including when using social media.
of personal and confidential information in a
way that is transparent and promotes trust. 3. We are cautious when discussing client matters in public spaces.
We gather, use, and keep personal, client, and
other confidential information only if we have 4. We take care to protect physical copies of confidential
a legitimate reason to do so. Access to this information.
information is provided only as necessary. Our
duty of confidentiality does not end when we leave 5. We promptly identify any unintended disclosure of confidential
PwC; we continue to respect the confidentiality information and escalate within PwC as appropriate.
of information even after our departure.

An understanding of the importance

of confidentiality and trust in one
another helps us collaborate, innovate
and succeed across the Network.
We use good judgment in the use of social
media, and never lose sight of the fact that
social media is public media. We think
before we post.

Living our Purpose and Values—PwC’s Code of Conduct 17

 Build trust in how we use information

We protect the information and physical and

electronic assets to which we have access. This What do we mean by “accidental”?
includes protecting them from all malicious
Accidental loss can occur by leaving a computer unattended,
threats and accidental loss.
inadvertently sending a confidential email to the wrong recipient, or
We secure all paper and electronic records and simply leaving sensitive documents at a printer site near your office.
keep them for only the prescribed period of time.

We preserve relevant information when we know

of or anticipate an investigation, litigation or What if ?
other matter, or have been instructed to do so.
I was in an office elevator, and No, this would be considered
We respect the integrity of our work papers overheard two people talking “insider trading.” We do not trade on
and do not make inappropriate changes to them about a merger and acquisition non-public information no matter
once they are complete. they were working on. Is it okay how we have obtained it. Also we
for me to invest in one of the should not disclose that information
We never trade on or inappropriately disclose to any other person. If not sure, you can find
inside information. companies?
additional guidance in the Insider Trading
policy. Remember that there are resources
that you can speak with as well, such as Risk
What is “inside information”? and Quality.

Inside information is information about a company (e.g., financial

forecasts, merger and acquisition proposals, and key personnel
changes) that has not been made public.

Where does inside information come from?

Inside information can come from any source (e.g., clients, suppliers,
subcontractors, joint venture partners, or any other entity or person
which PwC or anyone in PwC has contact with or information about).

Living our Purpose and Values—PwC’s Code of Conduct 18

 Build trust in how we use information

We are thoughtful in our communications,

online and off. We’re courteous and respectful
towards co-workers and clients when we
speak in public or online forums, use social
media, or take part in external dialogue.

When expressing views on community or

public issues, we are clear when such views are
our own and not necessarily those of PwC.

When audiences to whom we are speaking would

reasonably expect that we represent PwC, we
generally state only PwC’s view and not our own.
We do not express the views of others as our own.

We comply with copyright and intellectual

property laws.

What if ?
I found a really good research article on It depends. Remember that information on
the internet that I would like to share both the internet and PwC’s internal systems
with my colleagues and clients. Is it ok is often copyrighted and/or licensed
to do that? material, and you may need permission to
further circulate the information. Also, it is
important that you not use another’s work product as
your own. Attribution at a minimum is always
required, so that you are not accused of plagiarising.
If you are not sure, you should discuss with your
manager or engagement partner.

Living our Purpose and Values—PwC’s Code of Conduct 19

 RADAR: A framework
for deciding the
right thing to do
We are purpose led and values driven, and our
Purpose and values are our guiding principles
in deciding the right thing to do. Addressing
and resolving ethical dilemmas is complex,
and the Code cannot address all questions or
situations. The Code is one of many tools we
have as professionals to guide our behaviour.
It is not meant to be a rule book. The Code
is underpinned by the PwC Purpose and
values. It is supported and supplemented by
network standards, network and local policies
and guidance, all of which are available on
relevant sites throughout the network.

This RADAR decision making framework

is here to help you think and to build your
skills in analysing ethical dilemmas, and, in
doing so, make good decisions. In deciding
on a course of action, the steps and questions
can help guide your approach. They do not
need to be followed in any particular order,
and the following graphic is not meant to be
a decision tree. Rather, this is meant to help
frame your thinking, which could happen
within a few minutes to a few days. And
remember, nothing can replace individual
judgment and the application of the values
when deciding what to do in the moment.

Living our Purpose and Values—PwC’s Code of Conduct 20

 RADAR: A framework
for deciding the
right thing to do
Recognising
the event

Reporting and Assessing

communicating the situation

RADAR

Agreeing the Deciding

way forward what to do

Living our Purpose and Values—PwC’s Code of Conduct 21

 RADAR: A framework • Is the situation consistent with the PwC Purpose and
for deciding the values?
right thing to do • Are you being asked to do something which you think
is wrong, against the PwC Purpose or our values?
• Are you aware of others’ unethical or illegal behaviour
(e.g., colleagues, clients, suppliers and other parties)?
• Are you trying to make a decision but are unsure of
the ethical implications?
• Report your concerns to Recognising
appropriate resources (e.g., • What if it was reported in the media?
the event
ethics teams, OGC, R&Q, HC)
as necessary.
• Communicate your concerns
and rationale to the relevant
stakeholders, as appropriate.
• Reflect on what you have
learned and whether Reporting and Assessing Who is affected?
anything needs to change. communicating the situation
• You?
RADAR • A colleague/your team?
• PwC—your firm or the network?
• Your client/a client?
• Other third parties?
What are the guiding parameters?
• Test your decision—does it feel right? • Does it feel right?
Agreeing the Deciding
Can you sleep at night? way forward what to do • The law—is it legal?
• Would you be embarrassed if others • Regulation/professional standards.
knew what you did, or did not do? • What are the options?
• PwC standards and policies.
• Reflect on what a reasonable person • What are the likely results of each
would think. option? • Client reactions.

• Consult again, if necessary. • Is there an alternative solution that • Wider third party reactions.

• Act when you are confident with your does not pose an ethical conflict? • PwC Purpose.
decision, and always in good faith. • Consult as appropriate. • PwC values.
• Make a decision on what to do.

Building
Living ourtrust
Purpose and Values—PwC’s Code of Conduct Back DRAFT 22
 RADAR: A framework
for deciding the
right thing to do • Is the situation consistent with the PwC Purpose and values?
• Are you being asked to do something which you think is wrong,
against the PwC Purpose or our values?
• Are you aware of others’ unethical or illegal behaviour (e.g.,
colleagues, clients, suppliers and other parties)?
• Are you trying to make a decision but are unsure of the ethical
• Report your concerns to implications?
Recognising
appropriate resources (e.g., the event • What if it was reported in the media?
ethics teams, OGC, R&Q, HC)
as necessary.
• Communicate your concerns
and rationale to the relevant
stakeholders, as appropriate.
• Reflect on what you have
learned and whether Reporting and Assessing Who is affected?
anything needs to change. communicating the situation
• You?
RADAR • A colleague/your team?
• PwC—your firm or the network?
• Your client/a client?
• Other third parties?
What are the guiding parameters?
• Test your decision—does it feel right? Agreeing the Deciding
Can you sleep at night? way forward what to do
• Does it feel right?
• Would you be embarrassed if others • The law—is it legal?
knew what you did, or did not do? • What are the options?
• Regulation/professional
• Reflect on what a reasonable person • What are the likely results of each standards.
would think. option?
• PwC standards and policies.
• Consult again, if necessary. • Is there an alternative solution that
• Act when you are confident with your does not pose an ethical conflict? • Client reactions.
decision, and always in good faith. • Consult as appropriate. • Wider third party reactions.
• Make a decision on what to do. • PwC Purpose.
• PwC values.

Building
Living ourtrust
Purpose and Values—PwC’s Code of Conduct Back DRAFT 23
22
 RADAR: A framework
for deciding the
right thing to do • Is the situation consistent with the PwC Purpose and values?
• Are you being asked to do something which you think is wrong,
against the PwC Purpose or our values?
• Are you aware of others’ unethical or illegal behaviour (e.g.,
colleagues, clients, suppliers and other parties)?
• Are you trying to make a decision but are unsure of the ethical
• Report your concerns to implications?
Recognising
appropriate resources (e.g., the event • What if it was reported in the media?
ethics teams, OGC, R&Q, HC)
as necessary.
• Communicate your concerns
and rationale to the relevant
stakeholders, as appropriate.
• Reflect on what you have
learned and whether Reporting and Assessing Who is affected?
anything needs to change. communicating the situation
• You?
RADAR • A colleague/your team?
• PwC—your firm or the network?
• Your client/a client?
• Other third parties?
What are the guiding parameters?
• Test your decision—does it feel right? • Does it feel right?
Agreeing the Deciding
Can you sleep at night? way forward what to do • The law—is it legal?
• Would you be embarrassed if others • Regulation/professional standards.
knew what you did, or did not do? • What are the options? • PwC standards and policies.
• Reflect on what a reasonable person • What are the likely results of each
would think. • Client reactions.
option? • Wider third party reactions.
• Consult again, if necessary.
• Is there an alternative solution that • PwC Purpose.
• Act when you are confident with your does not pose an ethical conflict?
decision, and always in good faith. • PwC values.
• Consult as appropriate.
• Make a decision on what to do.

Building
Living ourtrust
Purpose and Values—PwC’s Code of Conduct Back DRAFT 24
22
 RADAR: A framework
for deciding the
right thing to do • Is the situation consistent with the PwC Purpose and values?
• Are you being asked to do something which you think is wrong,
against the PwC Purpose or our values?
• Are you aware of others’ unethical or illegal behaviour (e.g.,
colleagues, clients, suppliers and other parties)?
• Are you trying to make a decision but are unsure of the ethical
• Report your concerns to implications?
Recognising
appropriate resources (e.g., the event • What if it was reported in the media?
ethics teams, OGC, R&Q, HC)
as necessary.
• Communicate your concerns
and rationale to the relevant
stakeholders, as appropriate.
• Reflect on what you have
learned and whether Reporting and Assessing Who is affected?
anything needs to change. communicating the situation
• You?
RADAR • A colleague/your team?
• PwC—your firm or the network?
• Your client/a client?
• Other third parties?
What are the guiding parameters?
• Test your decision—does it feel • Does it feel right?
Agreeing the Deciding
right? Can you sleep at night? way forward what to do • The law—is it legal?
• Would you be embarrassed if others • Regulation/professional standards.
• What are the options?
knew what you did, or did not do? • PwC standards and policies.
• What are the likely results of each
• Reflect on what a reasonable person option? • Client reactions.
would think. • Is there an alternative solution that • Wider third party reactions.
• Consult again, if necessary. does not pose an ethical conflict? • PwC Purpose.

• Act when you are confident with your • Consult as appropriate. • PwC values.
decision, and always in good faith. • Make a decision on what to do.

Building
Living ourtrust
Purpose and Values—PwC’s Code of Conduct Back DRAFT 25
22
 RADAR: A framework
for deciding the
right thing to do • Is the situation consistent with the PwC Purpose and values?
• Are you being asked to do something which you think is wrong,
against the PwC Purpose or our values?
• Are you aware of others’ unethical or illegal behaviour (e.g.,
• Report your concerns to colleagues, clients, suppliers and other parties)?
appropriate resources (e.g.,
• Are you trying to make a decision but are unsure of the ethical
ethics teams, OGC, R&Q, implications?
HC) as necessary. Recognising
the event • What if it was reported in the media?
• Communicate your
concerns and rationale to
the relevant stakeholders,
as appropriate.
• Reflect on what you have
learned and whether Reporting and Assessing Who is affected?
anything needs to change. communicating the situation
• You?
RADAR • A colleague/your team?
• PwC—your firm or the network?
• Your client/a client?
• Other third parties?
What are the guiding parameters?
• Test your decision—does it feel right? • Does it feel right?
Agreeing the Deciding
Can you sleep at night? way forward what to do • The law—is it legal?
• Would you be embarrassed if others • Regulation/professional standards.
knew what you did, or did not do? • What are the options?
• PwC standards and policies.
• Reflect on what a reasonable person • What are the likely results of each
would think. option? • Client reactions.

• Consult again, if necessary. • Is there an alternative solution that • Wider third party reactions.

• Act when you are confident with your does not pose an ethical conflict? • PwC Purpose.
decision, and always in good faith. • Consult as appropriate. • PwC values.
• Make a decision on what to do.

Building
Living ourtrust
Purpose and Values—PwC’s Code of Conduct Back DRAFT 26
22
 We listen and take action The Code of Conduct, and
“Speaking up” is an essential first step. For any allegation, complaint, or the PwC network of firms
concern, we investigate and address the situation in an appropriate way. If
you want to learn more about the investigation process, and your options for We are committed to the spirit of cooperation among PwC network
anonymous reporting, contact your local ethics team. Remember that PwC firms. When faced with questions about business conduct or concerns
is committed to caring for and protecting our people against retaliation. when working for another firm within the PwC network, follow
the established policies of the host firm. If you’re not comfortable
Anybody who violates the PwC Code of Conduct or policies and procedures with raising the issue with the host firm, or are not satisfied with
will be held accountable. Those of us in the reporting line are responsible the outcome, raise the issue in your home firm so the issue can be
for addressing issues that are brought to our attention. addressed amongst the respective leaderships of the firms involved.
If anyone directs or approves violations, or has knowledge of them and does For further information, please visit: www.pwc.com.
not promptly move to correct them, he or she will be held accountable. We
are all responsible for cooperating during the investigation process, and for
answering questions truthfully, accurately, completely, and with integrity.
Failure to cooperate may result in disciplinary measures.

Living our Purpose and Values—PwC’s Code of Conduct 23

 Index
A Disrespectful behaviour 9 N S
Accountable 23 Disruptive behaviour 9 Network Risk Management Policies 2 Safety 9
Anonymous reporting 23 Diversity 8, 10 Network Standards 20 Sanctions 7
Anti-money laundering 7 Secure records 18
E O Serve clients 5
B Employment laws 15 Objectivity 5 Social media 17, 19
Bribe 7 Environmental impact 13 Online forums 19 Social problems 13
Bribery 7 Ethical dilemmas 20 Speak in public 19
Bullying 9 Expressing views 19 P Speak up 3, 10
Personal information 17 Speaking up 23
C F Political 14 Suppliers 6
Career development 10 Facilitation payments 7 Preserve information 18 Sustainable 13
Career growth 10 Fairness 9 Privacy 17
Charge for services 6 Professional authorities 14 T
Collaboration 9 G Professional growth 10 Tax Code of Conduct 15
Communications 19 Gifts 7 Professional obligations 14 Tax filings 15
Community activities 14 Government authorities 14 Professional standards 5 Tax planning 15
Compete fairly 6 Protect information 18 The Code in context 2
Competitors 6 H Public sector 7 Time and expenses 6
Confidential information 6, 16, 17 Harassment 9 PwC Professional 11 Traditions 13
Confidentiality 16, 17 Human rights 15 PwC resources 14 Trust 5
Conflicts of interest 5
Consult 3 I Q V
Continual learning 10 Inclusive 13 Quality 5 Values 1
Contracts 6 Independence 5
Contractual obligations 6 Information 17, 18 R W
Copyright 19 Inside information 18 RADAR 20, 21, 22 Work/life balance 10
Corporate responsibility 12 Insider trading 18 Record hours 6 Work papers 18
Corrupt practices 7 Intellectual property 19 Regulation 14 Workplace flexibility 10
Courtesy 9 International assignments 23 Relationships 11
Customs 13 Investigation 23 Represent PwC 19
Reputation 5
D L Respect 9
Decision making framework 20 Labour principles 15 Responsibility to report 3
Departure 17 Laws and regulations 5 Retaliation 3, 10, 23
Dignity 9 Legislation 14 Rule of law 14
Discrimination 9

Living our Purpose and Values—PwC’s Code of Conduct 24

www.pwc.com/codeofconduct
© 2021 PwC. All rights reserved. PwC refers to the PwC network and/or one or more of its member firms, each of which is a separate legal entity. Please see www.pwc.com/structure for further details. This content is for
general information purposes only, and should not be used as a substitute for consultation with professional advisors. PwC helps organisations and individuals create the value they’re looking for. We’re a network of firms in
157 countries with more than 195,000 people who are committed to delivering quality in assurance, tax and advisory services. Find out more and tell us what matters to you by visiting us at www.pwc.com

In this publication the terms “PwC”, “our” and “we” are used to refer to, collectively or interchangeably: (i) the individual PwC Professional, including partners/principals and staff, and/or (ii) the network
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