Overview
- What is personal independence?
- Why do we maintain personal independence?
- Who has to maintain personal independence?
- Who is an immediate family member?
- How can I learn more about personal independence at PwC?
What is personal independence?
- As a public accounting firm, PwC and its partners, employees, third-party contractors and their immediate family members must be independent of PwC’s audit clients, including their affiliates, to comply with applicable independence regulations. This includes being personally financially independent of PwC’s audit clients, including their affiliates.
To be financially independent means the financial arrangements of PwC partners, employees, third-party contractors and their immediate family members need to be permissible according to independence regulations and PwC policy.
Why do we maintain personal independence?
At PwC, we’re guided by our purpose to build trust in society and solve important problems. As a public accounting firm, PwC is expected by our clients and required by our regulators to maintain our independence and objectivity, in fact and appearance. It’s a critical characteristic of our profession and how PwC builds trust with our clients, society and in the capital markets.
Who has to maintain personal independence?
PwC partners, certain employees and third-party contractors — along with their immediate family members.
Who is an immediate family member?
- A spouse equivalent - is determined by you and is someone who you live with and consider your relationship to be similar to that of a spouse.
The following factors impact whether someone is your spouse equivalent:- Having a committed relationship that is ongoing and expected to continue indefinitely similar to that of a married couple, but having either chosen not to marry or unable to legally marry
- Having responsibility for each other’s welfare and financial obligations
- Providing or receiving coverage under each other’s medical insurance
- Co-owning the home in which you live together
- Living together and having children together
- Living together and being engaged to be married
- A dependent - anyone who receives more than half of their financial support from you whether or not they’re related to or live with you.
How can I learn more about personal independence at PwC?
Listen to the Personal independence for PwC family members podcast to learn more about your personal independence responsibilities and how to get help.
What is a financial arrangement and when is it permissible?
A financial arrangement is any of the arrangements described below. Permissible financial arrangements are those that are permitted by independence regulations and PwC policy.
Click on the financial arrangements below to learn more:
Investments
Examples of investments are stocks, bonds, mutual funds, money market funds, investment contracts, options such as puts and calls, other investments in a company and certain crypto tokens. Payment cards and wallets with an investment sweep option are also considered to be investments.
In certain circumstances, there are restrictions on owning investments in a company that is an audit client of PwC.
Checkpoint or the Compliance Resource Center can assess whether a particular investment is permissible (see more below). Once permissibility is determined, investments must be recorded in Checkpoint within five business days of any transaction.
Credit cards
Definition:
A credit card is a card issued by a bank which enables people to buy items without cash.
Caution statement:
It’s important to know the bank issuing the credit card. In certain circumstances for credit cards issued by a PwC audit client, there may be a requirement to maintain a balance below a certain threshold.
Checkpoint or the Compliance Resource Center can assess whether any independence-related requirements apply (see more below).
Insurance policies
Examples are automobile, boat, motorcycle, homeowner, second home, vacation home, title, renter, umbrella, accident, disability and life insurance policies.
In certain circumstances, there are restrictions on entering into a new or making changes to an existing insurance policy with a PwC audit client.
Checkpoint or the Compliance Resource Center can assess which insurance policies are permissible (see more below).
Depository accounts
Examples of depository or bank accounts are checking, savings and money market accounts.
In certain circumstances, there are restrictions on using certain bank account features offered by a PwC audit client, such as overdraft protection or having a balance which exceeds Federal Deposit Insurance Corporation (FDIC), or similar insurance, limits.
Checkpoint or the Compliance Resource Center can assess whether any independence-related restrictions apply (see more below).
PayPal and Venmo
Certain online accounts, such as PayPal and Venmo (a service of PayPal), provide the opportunity to hold cash on account.
In certain circumstances, there are restrictions on holding an overnight balance with certain online accounts offered by a PwC audit client.
Checkpoint or the Compliance Resource Center can assess whether independence-related requirements apply (see more below).
Loans and mortgages
Examples are home, vacation and investment property mortgages and unsecured lines of credit.
In certain circumstances, there are restrictions on entering into new or making changes to an existing loan or mortgage with a PwC audit client. In addition, timely payments may be required.
Checkpoint or the Compliance Resource Center can assess which lenders are permissible and whether any other independence-related requirements apply (see more below).
Material leases
Any lease (other than automobile leases and leases from individuals) where the sum of the annual lease payments comprise 5% or more of the household’s gross annual income. The most common example is an apartment lease.
In certain circumstances, there are restrictions on entering into or making changes to an existing material lease with a PwC audit client.
Checkpoint or the Compliance Resource Center can assess which lessors are permissible (see more below).
Brokerage and investment accounts
A brokerage or investment account is an account that enables buying and selling of investments usually through a designated broker, financial advisor or automated advisor. These include demat, asset management, security holding and cash management accounts, along with managed accounts and discretionary accounts.
PwC has restrictions on which investment firms PwC partners, employees, third-party contractors and their immediate family members may maintain an account with.
Even if the investment firm is permissible, there may be restrictions on the account features such as automatic investing, money market sweep and margin options.
Checkpoint or the Compliance Resource Center can assess which investment firms are permissible and whether any other independence-related restrictions apply (see more below).
Employer-sponsored plans
An employer-sponsored plan is a plan established by a company to provide retirement and savings benefits to its employees. Common plans include 401(k), 403(b), 457(b), pension plans, profit sharing plans, employee stock ownership plans, employee stock purchase plans, Employee Provident Funds, Private Retirement Schemes (PRS), individual retirement accounts (IRA) and health savings accounts (HSA).
Any US-based former employer-sponsored plan of a PwC partner, employee, or their immediate family members must be rolled over to an account with a permissible brokerage firm or into a current employer-sponsored plan.
Checkpoint or the Compliance Resource Center can assess which brokerage firms and investments are permissible (see more below). Once permissibility is determined, the investments held through the plan must be recorded in Checkpoint within five business days of any transaction.
College savings plans
A college savings plan is a tax-advantaged investment account used to pay for education-related expenses. These plans include 529 college savings plans, prepaid tuition plans, child education savings accounts and education funds.
Not all college savings plans are permissible.
Checkpoint or the Compliance Resource Center can assess which plans are permissible. Once permissibility is determined, the plan must be recorded in Checkpoint within five business days of investing in the plan.
Trusts, estates and powers of attorney
Trusts, estates and powers of attorney are types of legal agreements where an individual may exercise control over another individual’s financial assets.
If you or your immediate family members have been granted powers of attorney, are a trustee, co-trustee or grantor of any trust, or are an executor or administrator of any estate, any financial relationships held by the person over whom you or your immediate family members have the power of attorney, trust or estate must be treated as your financial relationships. This includes any accounts owned by another person where you have trading authority over the accounts.
Checkpoint or the Compliance Resource Center can assess whether a particular financial relationship is permissible (see more below).
Other businesses under your control
Control of a business generally exists when an individual or entity owns more than 50% of another entity.
Personal independence requirements apply to any financial relationships related to any business over which you or your immediate family members have control.
Checkpoint or the Compliance Resource Center can assess whether any independence-related restrictions apply (see more below).
What’s the best way to determine the permissibility of a financial arrangement?
It’s critical to confirm financial arrangements are permitted by independence regulations and PwC policy. Permissibility must be determined before entering into a new financial arrangement or making changes to an existing financial arrangement.
There are three options to determine the permissibility of a financial arrangement:
The Compliance Resource Center is a dedicated resource to help PwC partners, employees, third-party contractors and their immediate family members maintain personal independence, including assessing the permissibility of a financial arrangement.
The Compliance Resource Center can be contacted by calling:
- 1-877-PwC-Help (in the US)
- 800-444-0103 (in Mexico)
- +91 0008000404620 (India Acceleration Center employees)
- +86-2160366800 option 4 (Shanghai Acceleration Center employees)
- +63 (02) 7720-6900 (Manila Acceleration Center)
- 1-813-351-6491 (other countries outside the US)
Note: International charges may apply outside these areas.
CRC Hours:
US & Mexico: Monday – Thursday 8am – 7pm ET, Friday 8am – 6pm ET
All other locations: Monday – Friday 9am until 6pm IST
Note: All chats close an hour before closing.
PwC partners and their immediate family members, have dedicated Ethics & Compliance Partner Outreach support — with multiple ways to get assistance with any personal independence questions.
This proprietary tool informs PwC partners and employees (and their immediate family members and financial advisors) which financial arrangements are permissible and alerts them if a financial arrangement becomes impermissible.
- PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.
Be aware that Checkpoint may indicate a permitted status because it is a PwC audit client, including its affiliates. But remember, even if there is a green (Permitted) checkmark, PwC partners, employees, third party contractors and their immediate family members can’t buy or sell investments in any entity if they’re in possession of material, non-public information and must be aware of certain prohibitions on trading time period related to non-audit clients.
PwC partners and employees can pre-clear financial arrangements using Checkpoint.
- PwC partners and employees can also grant Checkpoint access to immediate family members and financial advisors, enabling them to pre-clear financial arrangements themselves.
