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Global Third Party Code of Conduct Summary

Introduction

PwC is a global leader in professional services, dedicated to building trust in society and solving important problems. The Third Party Code of Conduct outlines the minimum standards of integrity and business conduct that PwC expects from its Third Parties. The code is aligned with the United Nations Global Compact (UNGC) and OECD Guidelines for Multinational Enterprises, which provide a framework for responsible business conduct.

Core Values and Standards

PwC's core values include:

• Act with integrity
• Make a difference
• Care
• Work together
• Reimagine the possible

These values are reflected in the following key standards:

• Speak up: PwC encourages raising concerns in good faith and protects against retaliation.
• Compliance: Third Parties must comply with local and international laws, as well as this Code.
• Due diligence and monitoring: Third Parties must have processes to ensure compliance, and PwC may conduct risk-based due diligence.
• Independence: PwC maintains independence in its assurance services, and Third Parties may be required to comply with similar obligations depending on their relationship.
• Conflicts of interest and sensitive situations: Third Parties must identify and address conflicts of interest and sensitive situations promptly.
• Competing fairly: Third Parties must not engage in anti-competitive practices, including price-fixing or client allocation.
• Combatting corruption and bribery: All forms of corruption, including facilitation payments, are strictly prohibited.
• Economic crime and money laundering: Third Parties must not facilitate or engage in economic crime, including money laundering and terrorist financing.
• Insider dealing/trading: Third Parties must not trade on or disclose inside information.
• Sanctions and export controls: Third Parties must comply with applicable economic sanctions and export control laws.
• Environmental stewardship: Third Parties are expected to identify and manage environmental impacts, minimize greenhouse gas emissions, and promote sustainability.
• Confidentiality and data protection: Third Parties must protect PwC's and its clients' confidential information and handle data only as authorized.
• Intellectual property: Third Parties must respect and not misuse PwC's or others' intellectual property.
• IT security: Third Parties must use security controls that meet PwC's requirements to protect information and assets.
• Social media: Third Parties must use social media responsibly and not represent PwC or express its views without authorization.

Key Expectations for Third Parties

• Ethical and legal compliance: Adherence to local and international laws, as well as PwC's Code, is mandatory.
• Reporting mechanisms: Third Parties are expected to report concerns in good faith through designated channels, including PwC's Global Ethics and Compliance helpline.
• Non-retaliation: Third Parties must ensure that their Personnel are not retaliated against for raising concerns.
• Transparency: Third Parties must provide complete and accurate information to PwC for due diligence purposes.
• Accountability: Third Parties are responsible for their own conduct and must exercise good judgment and obtain guidance where necessary.
• Human rights and labor standards: Third Parties must maintain working conditions that meet international human rights and labor standards, including non-discrimination, fair wages, and safe working environments.
• Prohibition of child labor and modern slavery: Third Parties must not use child labor or engage in human trafficking or modern slavery practices.
• Freedom of association: Third Parties must allow their Personnel to lawfully form and join organizations and associate freely.

Conclusion

The Global Third Party Code of Conduct is a comprehensive framework that outlines PwC's expectations for ethical, legal, and responsible business practices. It emphasizes integrity, fairness, compliance, and respect for human rights and the environment. Third Parties are expected to adhere to these standards, support PwC's values, and maintain transparency and accountability in their operations.