Doing business ethically in times of COVID-19
To act in a legitimate manner and according to the highest ethical standards is the responsible way to conduct a business. Our employees, clients and public are entitled to expect that type of behaviour from business leadership.
At PwC Luxembourg, we are aware that ethical behaviour, values and purpose are fundamental for our business, and for the trust our clients, communities and people place in us. These aspects—guided by our Code of Conduct— are what enables us to adapt to global challenges and thus remain a resilient and relevant business partner for our stakeholders. We promote and enact a responsible business internally— through an Ethics and Business Committee—as well as externally, by only serving clients that are approved by our Client Acceptance Committee, who value our service and meet appropriate standards of legitimacy and integrity.
Introducing an independent chairman
The role of PwC Luxembourg’s Ethics and Business Committee is twofold. Firstly, its members ensure that we are aligned with our Code of Conduct and that we do business in a responsible and ethical way that is consistent with our values. For instance, they address topics such as legitimacy, confidentiality, conflict of interest and anti-bribery, and make sure these topics are handled in a proper manner. Secondly, the Committee is there to encourage our employees to speak up when they find themselves in a dilemma or in a situation that does not seem right.
In addition to the 20 Ethical Counsellors we introduced last year, this year we took the decision to start working with an independent chairman, who will be a part of our Ethics and Business Committee. This is the first time PwC Luxembourg is working with someone independent from process management, and we believe that it will reinforce the way we promote and perceive ethics (such as our Speak Up culture) and business conduct within our organisation.
In deciding who will be our independent chairman, it was extremely important that it was someone who we can trust and who knows us well, while also being an honest, people-centric and values-driven individual. This led us to choosing Paul Neyens, a PwC Luxembourg alumni Partner and also the former PwC HR Leader. After leaving PwC five years ago, Paul Neyens had a career break and has since been working as a volunteer for different non-for-profit organisations, including the Belgium Red Cross. We believe that including someone in the Ethics and Business Conduct Committee from a different sector and with an external perspective will reinforce the original role of the Committee: to ensure that we live up to our Code of Conduct and further promote our Speak Up culture.
Paul Neyens will be working alongside Philippe Sergiel, our new Ethics and Business Conduct Leader. While we are very excited to welcome our new Ethics Leaders, we must also give a big thank to our former Ethics and Business Conduct Leader, Thierry Blondeau. Together, Paul Neyens and Philippe Sergiel will be supported with a new Ethics and Business Conduct Committee, which is composed of a delegate of four individuals, one from each of our four lines of service, as well as one Ethics Officer. In addition, they will also be working with the Ethics Counsellors.
We believe that fostering trust levels with our people forms the basis for restoring public trust.
This material makes reference to GRI disclosure 102-17
This material makes reference to WEF Core Disclosure - Principles of Governance - Ethical Behaviour - Protected ethics advice and reporting mechanisms
“Ethics and values are important drivers for me. I had excellent experience and memories within PwC Luxembourg and I am glad to be back just after five years assuming a completely different role for the benefit of the firm, employees and Partners. Together with the members of the Committee and the Ethics Counsellors, we are willing to promote the Speak Up culture. Be assured that by contacting us, discussions are kept confidential and no retaliation is tolerated.”
Client Acceptance
It is equally as important for us to align our clients with our Code of Conduct and our values, as it is for our employees. Furthermore, we also believe that we can have a societal impact through our decision to accept a client or not. Our Client Acceptance Committee is in place to ensure just this.
Client Acceptance Committee
PwC Luxembourg’s Client Acceptance Committee reviews whether our clients are in accordance with PwC Global’s acceptance rules, making sure that they respect a certain number of principles. In addition to complying with laws and regulations and in particular strict ones related to AML and sanctions, we ensure that our clients are of good standing and that they are in line with our Code of Conduct and values.
Based on this approach, we do refuse to work with clients from time to time due to the questionable ethical nature of their activities and we discontinue relationships with some clients when they are no longer aligned with our values and ethical standards. Even if the activity is fully legal, we do not want to support and indirectly encourage or endorse these kinds of activities.
We pay particular attention to the location of the business of our clients, for example when they are located in high risk countries as per the Financial Action Task Force (FATF) lists, as they are more likely to be exposed to corruption risk. Besides that, all potential clients in specific activities, such as internet gambling, e-money, cyber activities, art, jewellery, arms trading, sensitive raw materials (e.g. uranium) and adult entertainment require special approval. We initiate the deselection process in cases where clients are not willing to pay a fee appropriate for our services, when they put pressure on the quality of our work, or when they are willing to pay fees that are too high.
This material makes reference to GRI disclosures 102-16 ; 102-44 ; 102-46a ; 102-46b ; 102-47 ; 103-1 ; 103-2 ; 103-3
