Understand your personal independence obligations as an immediate family member of a PwC professional.
As an audit firm, our regulators require us to remain independent of our audit clients. This is so that we are always objective and can maintain integrity when dealing with our clients. Some of these rules may impact you, and you therefore play an important role in helping our people meet their obligations. We know that the rules we have to follow are not always easy to understand, so this webpage has been designed to help demystify these and help you navigate what it means to be associated with someone who works at PwC.
Is this information relevant to me?
Some of the rules that your PwC professional has to comply with also have an impact on what the regulators term ‘immediate family members’. So what does this mean?
Immediate family members include:
- Spouse: relationship is formalised either by marriage or under common law.
- Spousal equivalent: someone the PwC professional lives with and shares an ongoing intimate relationship with, regardless of whether their finances are handled separately.
- A dependent: anyone, whether related or not, who receives substantial financial support from the PwC professional (e.g. children).
Are you an immediate family member of a PwC professional?
Why we need your help
If you are an immediate family member, your PwC professional needs your help to ensure they are demonstrably impartial and objective in their work.
This is important because:
- it is a requirement imposed on us by our regulators;
- even an inadvertent failure to comply with these professional standards can expose PwC to legal and regulatory risk or a loss of public confidence in our work;
- remaining independent provides comfort to our audit clients and retains public confidence in capital markets; and
- there are consequences for your PwC professional for getting this wrong.
How you can help
By reading this, you’re already showing your support in helping our people maintain their personal independence — thank you.
Below are the next steps you can take to help your PwC professional stay on track with their personal independence:
- Collate all the financial interests you have (e.g. investments in shares/funds/pension policies/crypto tokens) including anything acquired via any online trading apps by making a list. Remember, they don’t need to know the value, just who the investment is with.
- They will need to record your financial interests in Checkpoint (PwC’s personal independence software tool). Having the unique identifier for each of your investments, such as an ISIN or SEDOL code, will make this much easier for them.
- Before making a new investment, please talk to your PwC professional and ask them to check if it is permitted to buy by pre-clearing it in their Checkpoint.
- When purchasing a new, pre-cleared, investment, please tell your PwC professional as soon as possible, as they are required to log this within Checkpoint within 14 days.
- After fully selling investments, again please tell your PwC professional as soon as possible so that they can remove these from their Checkpoint portfolio within 14 days.
How to help
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Collate
Collate all the financial investments you have in written notes or a digital document.
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Record/check
Remind your PwC professional to record all your investments in Checkpoint, PwC’s personal independence tool.
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Update
Talk to your PwC professional regularly about your financial affairs to ensure everything is kept up-to-date.
Want to know more about personal independence?
The information below provides you with more detail about personal independence and its importance for PwC partners and employees.
What is personal independence?
As an audit firm, our people must be independent of our audit clients to comply with regulatory requirements. This is set out in the IAASA and FRC’s Ethical Standards, which focus on ensuring audit firms appropriately manage threats to integrity, objectivity and independence.
Staying personally independent means that decisions our people make at work are wholly independent of their own financial and personal relationships, and you play a key role in helping to achieve this.
To be personally independent means our people have the appropriate financial and personal relationships, including:
- financial interests (e.g. shares and funds);
- financial arrangements (e.g. bank accounts and credit cards); and
- relationships (e.g. employment).
Your PwC professional may therefore need to have conversations with you about some or all of these areas.
The main way our people demonstrate their independence is by logging all financial interests held by themselves and their immediate family members on our personal independence logging system, called Checkpoint.
Remember, the PwC professional you’re associated with doesn't need to know the value of any of your investments, just what you are invested in.
Why independence matters?
Complying with PwC’s personal independence policy will help our people remain safe from reputational risk and protect them from significant penalties.
Protect
Help protect against any regulatory issues and potential personal reputational damage.
Minimise losses
Reduce the likelihood of losses on your investments owing to non-compliance.
Build trust
Ensuring all our employees are independent helps us to maintain and build trust in society.
When might things change?
Life events can change your personal independence responsibilities.
Life events can change your personal independence responsibilities.
If you’re unsure about how your recent life change may affect your shared personal independence responsibilities, get your PwC professional to reach out to the Independence Team.
Or if you’re an immediate family member of a PwC professional, you can email the Independence Team for further guidance or to discuss any concerns you might have.
