Ethics & Compliance
Independence Overview
What is “Independence” and why is it important?
PwC operates in a highly regulated environment, and the By auditing clients’ financial statements and providing a
firm is subject to a number of regulations that help us broad range of other professional services, PwC as a firm
maintain the public‘s trust, including independence and our partners and staff as individuals commit to
rules established by the SEC, PCAOB, and AICPA, being independent of our audit clients and their affiliates
among other regulators. (called “restricted entities”). Our reputation depends on
us being unbiased and free from any conflicts of interest
The word “independence” refers to the ability of our
with clients at all times.
professionals to act with integrity, objectivity and
impartiality in all of our work. Staying independent
means we have to consider our personal financial
interests, any employment and business relationships we
pursue, and fee arrangements we enter into.
How will “Independence” affect you?
If you choose to accept employment with PwC, PwC’s Ethics & Compliance Office (E&C) makes many
independence rules may impact your personal financial resources, programs and tools available to help you
interests, as well as those of your spouse/spouse maintain your independence and other compliance
equivalent and any dependents responsibilities throughout your career at PwC.
you support.
Everyone who accepts an offer of employment with PwC
The rules can be complex and depend on such participates in a “personal independence clearance
factors as staff level, specific role at the firm, client process” to determine actions you may need to take
assignments, and work office location. regarding your investments and other financial
arrangements (loans, mortgages, etc.) prior to joining
the firm.
Independence considerations
Relationships with restricted entities (PwC audit clients or their affiliates) that can be impacted include:
• Stocks, bonds, mutual funds, 529 Savings Plans and other types of investments
• Brokerage accounts, including margin loans, cash management and other similar accounts
• Banking or checking accounts with balances over $250,000
• Credit cards with balances that exceed $10,000
• 401(k) plans or other employee benefit plans with a current or former employer
• Mortgage on any type of property
• Insurance coverage, such as a whole life, universal, homeowner or renter, vehicle, or variable life
insurance product
• Participation in a partnership, service as a member of a board, or as an executor or trustee
To discuss these topics with PwC prior to making your employment decision, please contact the
PwC Compliance Resource Center at 1-877-815-8616 in the US (or 1-201-521-3328
outside US).
About the “personal clearance process”
The personal clearance process requires an investment In certain cases, if you have a personal financial interest
of effort and time. The benefit is that you know you are or relationship with a PwC restricted entity (an audit
joining a firm with a long legacy of earning the trust of client and its affiliates), you may be asked to change
clients, the public and the regulators. those relationships before you can join the firm.
Generally, the independence rules governing personal At any time if you have questions about the personal
financial interests apply to partners and staff who clearance process or how the independence rules
directly provide professional services to clients or might impact you, contact the PwC Compliance
have significant direct contact with clients. The Resource Center.
personal clearance process is an important step in
assessing independence.
Before you start: PwC’s “personal clearance process”
• Upon accepting PwC’s offer of employment, you will receive details and instructions for how to complete
the personal clearance process.
• As part of the personal clearance process, you may be required (depending on your role with the firm) to
provide information regarding your financial interests and arrangements (e.g., redacted statements of
securities such as stocks and mutual funds, 529 Savings Plans, 401(k) plan investments, loans, mortgages)
as well as your CPA licenses, if applicable.
• You will not be asked for specific financial information, such as the number of shares you own. The
information you submit will be reviewed to determine whether you need to take any actions to become
compliant with PwC’s Independence Policy prior to starting with the firm.
• PwC may conclude that certain roles are exempt from certain independence rules; however, everyone,
regardless of role, will be required to complete the personal clearance process before beginning
employment with PwC.
Independence resources
PwC’s Ethics & Compliance Office has many resources to help you understand the rules and how they might
impact you and your family, if you choose to accept employment with PwC.
If you have any questions regarding the personal PwC Compliance Resource Center
clearance process, independence rules, CPA 1-877-815-8616 (inside the US)
requirements or any other compliance matter, 1-201-521-3328 (outside the US)
please contact us -- either before you accept
employment, or after you join the firm.
The information provided here is not intended to be comprehensive. You will receive additional
details and instructions upon accepting PwC’s offer of employment.
© 2016 PwC. All rights reserved. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Each member firm is a separate legal entity.
Please see [Link]/structure for further details.