PwC Bangladesh Third Party Code of Conduct
Document status
Released - V1.0
Date
September 19, 2016
© 2016` PricewaterhouseCoopers. All rights reserved. "PricewaterhouseCoopers" and "PwC" refer to the network of member firms of
PricewaterhouseCoopers International Limited (PwCIL). Each member firm is a separate legal entity and does not act as agent of PwCIL or any
other member firm. PwCIL does not provide any services to clients. PwCIL is not responsible or liable for the acts or omissions of any of its member
firms nor can it control the exercise of their professional judgment or bind them in any way. No member firm is responsible or liable for the acts or
omissions of any other member firm nor can it control the exercise of another member firm's professional judgment or bind another member firm or
PwCIL in any way.
PwC Bangladesh Third Party Code of Conduct
1. Introduction
PricewaterhouseCoopers Bangladesh Private Limited (herein referred to as ‘PwC Bangladesh’1)
conducts its business within the framework of applicable laws, and regulations, together with
PwC policies and highest professional standards. The PwC experience is enshrined in our
values - acting professionally, doing business with integrity, upholding the reputation of clients
and PwC, treating people and environment with respect, and acting in a socially responsible
manner. In order to reinforce the commitment to our values and operate in a manner that
reflects high ethical standards, PwC Bangladesh has developed the Third Party Code of
Conduct ("Code") which is applicable to you as a Third Party2, and to all personnel employed
directly or indirectly by you, including agents and subcontractors where applicable, to provide
goods or services to PwC Bangladesh or to PwC Bangladesh’s current or prospective clients.
While PwC Bangladesh recognizes that there are different cultural environments in which
Third Parties operate, this Code sets forth the basic requirements that you must meet in order
to do business with PwC Bangladesh. PwC Bangladesh requires that you comply with all
applicable laws, rules and regulations, and with this Code.
2. Compliance with Laws, Regulations and Business Conduct
In addition to observing the law, compliance with this code also means conducting business in
a way that you fulfil all your ethical responsibilities to the persons and society at large in both
letter and spirit. Where local laws are less restrictive than this Code, you must comply with all
the tenets of this Code as applicable, even if your conduct would otherwise be lawful. On the
other hand, if local laws are more restrictive than this Code, you must always, at a minimum,
comply with those local laws in strictest terms.
The Third Party shall comply with all applicable laws, statutes, ordinances, rules, regulations
and orders applicable and material to the provision of services and/or supply of goods in
connection with PwC Bangladesh’s business or the business of PwC Bangladesh’s current or
prospective clients. This includes all applicable data privacy and protections laws (if any), laws
and regulations pertaining to non-discrimination, affirmative action, labour, wages, hours and
other conditions of employment (the "Laws"). Third Parties shall at their expense secure all
permits, licenses, certifications, regulatory approvals and authorizations (collectively,
“Authorizations”) required by the laws and shall take all steps necessary to maintain
documentation of such authorizations, at all times. Third Parties shall provide adequate
documentation for proof of compliance with laws, upon request by PwC Bangladesh. If the
Third Party is unable, after exercising reasonable diligence, to secure or maintain such
authorizations, PwC may terminate the engagement without liability.
PwC Bangladesh strives to develop mutually beneficial business relationships and expects you
to adhere to high ethical standards and avoid engaging in any activity that involves even a
perception of impropriety or any adverse reputational risks to PwC. In relation to PwC
Bangladesh’s business or the business of PwC Bangladesh’s current or prospective clients,
Third Parties may be required to furnish details including, but not limited to the following:
a. Original records of any statutory filings,
b. Paid invoices of your Consultants/sub contractors, where applicable,
c. Audit reports and other books and records.
1PwC
Bangladesh/ is a member firm of the network of member firms of PricewaterhouseCoopers International Limited
(PwCIL).
2Third
Party includes any individual or entity acting as a vendor to or supplier of PwC Bangladesh, acting on behalf of PwC
Bangladesh, under the supervision of PwC Bangladesh, or jointly with PwC Bangladesh, engaged in order to market or deliver
services, in connection with PwC Bangladesh’s business or the business of PwC Bangladesh’s current or prospective clients. Such
individuals or entities may include but are not limited to consultants, advisors, lawyers, surveyors, specialist valuers, software
suppliers, and/or other specialists. Third Parties are further categorized based on the purpose for which they are engaged.
These categories include Joint Business Relationship (JBR) partners, Subcontractors, Vendors or Suppliers.
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2.1 PwC Bangladesh Anti-Corruption Policy for Third Party Compliance
Third Parties are required to read, understand and comply with PwC Bangladesh AntiCorruption Policy for Third Party Compliance. Third Parties are required to confirm the same
through periodic declarations as required under the PwC Bangladesh Anti-Corruption Policy
for Third Party Compliance.
2.2 Business Courtesies
The Code does not permit Third Parties to accept or provide any business courtesy, gift, meals,
entertainment, gratification, any valuable thing without consideration or for inadequate
consideration from/to commercial parties, government officials, PwC Bangladesh
partners/staff or other third parties in violation of the PwC Bangladesh Anti-Corruption Policy
for Third Party Compliance.
2.3 Anti Trust and competition Laws
Third Parties must comply with relevant antitrust or competition laws at all times and not
indulge in any anti-competitive practices whether by itself or in combination with other
entities. These laws are designed to protect consumers and competitors against unfair business
practices and to promote and protect healthy competition.
2.4 Labour Laws
The Third Party shall be solely and absolutely responsible for salary, allowance and other
statutory dues of its employees/ staff. The Third Party shall ensure full compliance of all
applicable statutory regulations including Provident Fund, Employee Insurance, Workmen
Compensation, Minimum Wages, and Bonus in respect of employment of its employees/staff
and shall indemnify PwC Bangladesh against any claims arising out of the same. The Third
Party shall obtain and maintain its registration, authorisation, licenses and permits, as
applicable under various statutes. The Third Party shall also ensure that its employees/staff
abide by this Code of Conduct. The Third Party shall also comply with all other applicable
labour laws, including those dealing with child/forced labour and workers safety and health.
2.5 Trade Embargoes
Comprehensive sanctions have been imposed by UN, US, EU and other countries against
various regimes. Third Parties should ensure compliance with such sanctions which are
dynamic in nature and be aware of the financial and reputational consequences in case of
breach. Third Parties can obtain from PwC Bangladesh a list of countries on whom sanction
have been imposed, as maintained and updated from time to time.
2.6 Subcontractors
Wherever applicable, a Third Party may utilize the services of a subcontractor only with PwC
Bangladesh’s prior written approval and at PwC Bangladesh’s sole discretion. PwC Bangladesh
shall have the right at any time to withdraw approval and consent with respect to the Third
Party’s use of a particular subcontractor. While engaging a subcontractor, the Third Party shall
ensure that:
a. All such subcontractors conform to and comply with the stipulations of this Code of
Conduct.
b. Adequate monitoring processes, including periodic audits of the subcontractor's
records, are put in place by the Third Party.
c. PwC Bangladesh has the right to inspect and review any sub contractor's records and
processes in the same manner PwC Bangladesh has the right to review the Third Party.
d. No agreement entered into by the Third Party with a subcontractor or other personnel
shall provide for any indemnity, guarantee or assumption of liability by PwC
Bangladesh.
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e. No subcontractor shall be deemed a Third Party beneficiary for any purposes under this
Code of Conduct, notwithstanding any agreements contained herein that may operate
to the benefit of such subcontractor.
f. The Third Party shall be fully responsible and liable for all acts or omissions of its
Subcontractors.
2.7Financial Integrity
Third Parties financial books, records, and statements shall properly document all financial
information and accurately reflect all transactions undertaken as per your agreement with PwC
Bangladesh. Third Parties business records must be retained in accordance with applicable
laws and regulations.
3. Confidentiality and Security
Third Parties are required to protect confidential information to which they have access, in
connection with their business with PwC Bangladesh and secure such confidential information
against unauthorised disclosure, access or use. Third Parties must adhere to any confidentiality
terms agreed with PwC Bangladesh. If a separate confidentiality agreement does not exist,
Third Parties should presume that all information available from PwC Bangladesh is
confidential. Third Parties are required to safeguard personal privacy and comply with
applicable privacy and information security laws and regulations including the Information
and Communication Technology Act, 2006 and the Rules/ Regulations made thereunder.
Third Parties must have comprehensive HR processes, security awareness program and
background check process for all employees, staff and other personnel who will access the
facilities, networks, confidential information, or have custody of tangible, intangible and
electronic assets or work products of PwC Bangladesh or PwC Bangladesh’s current or
prospective clients. Third Parties shall also ensure that all confidential information of PwC
Bangladesh is protected in accordance with highest industry standards and having full regard
to local enactments in this regard.
4. Conflicts of Interest
The term 'conflicts of interest' describes circumstances that could cast doubt on a Third Parties
ability to act with total objectivity with regard to PwC Bangladesh’s interests. PwC Bangladesh
requires all its third parties to be free from any conflicts of interest. Conflict of interest
situations may arise in many ways. If an actual or potential conflict with PwC Bangladesh or
any of its Partner/staff is identified, Third Parties must report all pertinent details as required
under point#7 below.
5. Independence
PwC Bangladesh works in a regulated profession, with specific standards around maintaining
independence. This is fundamental to giving clients, regulators and the public, confidence in
our ability to act with integrity, objectivity and impartiality. Failing to maintain independence
can have serious consequences including exposure to legal and regulatory action, that can
impair PwC Bangladesh’s reputation and lead to loss of public trust. In order to facilitate PwC
Bangladesh’s adherence with applicable independence regulations, all third Parties must
prudently manage risk and make decisions unencumbered by personal interests. Third parties
should also promptly provide PwC Bangladesh with timely, accurate, and complete
information which is necessary to ensure compliance with applicable independence
regulations.
6. Discrimination
PwC Bangladesh expects all Third Parties to provide a work environment free from all
discrimination, harassment, and retaliation. All Third Parties shall employ workers on the
basis of their ability to do the job, not on the basis of their personal characteristics or beliefs.
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As such, PwC Bangladesh expects you to employ workers without regard to race, colour,
gender, nationality, religion, age, disability, familial or marital status, or sexual orientation or
any other category protected by the applicable laws and regulations. In addition the third
Parties shall have duly documented internal procedures and guidelines to maintain objectivity
in matters of employment, employee safety etc.
7. Monitoring and Enforcement
As a condition of doing business with PwC Bangladesh, all Third Parties must comply with this
Code. PwC Bangladesh will continue to develop monitoring systems to assess and confirm
compliance to this Code which may include right to conduct regular audits of the processes and
documentation of the Third Party and employ such other measures which PwC Bangladesh
may prescribe from time to time.
If PwC Bangladesh determines that any Third Party has violated this Code, PwC Bangladesh
may either terminate the services, its business relationship or require the Third Party to
implement necessary corrective actions. If corrective action is advised, but not taken, PwC
Bangladesh will suspend placement of future orders and shall terminate its current business
relationship.
8. Reporting Concerns
Third Parties are obliged to report concerns related to real or perceived wrongdoing and/or
violations of this Code or other laws, regulations, etc, and any other concerns that arise during
the course of doing business with PwC in Bangladesh, using the following methods:

Ethics Email address (ethics.india@in.pwc.com );
 Global Helpline (www.pwc.com/ethics, click on 'Contact us').
Concerns should be reported honestly and in good faith. Such reporting may be made
anonymously if preferred.
PwC Bangladesh will review/investigate all reported complaints or concerns. Third parties are
required to fully and promptly co-operate with any inquiry/investigation process initiated by
PwC Bangladesh and must respond fully and truthfully to any questions, requests for
information, or documents.
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