Annex A Independence and Other Declarations · 2020. 2. 10. · Annex A Independence and Other...

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Annex A Independence and Other Declarations (non-CF Client Service Staff) Page 1 of 2 Independence and Other Declarations These declaration forms are submitted in support of your employment contract. You are required to complete the applicable pages in typewritten format (by typing in the editable fields), and only e-signatures should be used. I hereby confirm that: (b) I do not hold any positions mentioned in Paragraph 1 (a) above and I am not engaged in other forms of remunerative employment, except for those described in the Other Employment/Business Interest Application Form (Annex A-1). Is Annex A-1 form attached? (c) I will ensure that any other employment/business interest not approved by PwC will be relinquished prior to commencement of my employment with PwC Singapore. Confidentiality/Insider Trading/Privacy Statement 2. I agree to comply with all confidentiality obligations in relation to client and non-client information not available to the public which may come into my possession during my employment with the firm. I further confirm that I will not exploit such information in any way. I understand that the firm and client information, including firm software, methodologies, and manuals, not available to the public, that are obtained as a result of my employment or any services rendered by the firm, may not be disclosed to others, exploited in any way, or retained by me when I leave the firm. I acknowledge that I understand and consent to your use of my personal data in accordance with the Privacy Statement set out in this letter or as updated from time to time by notification from the firm. IT Security Policy 3. I have read and am aware of the importance of proper use of information technology (IT) in the firm (Annex D). In accepting the employment offer, I agree to comply fully with the firm’s IT security policy at all times. Bankruptcy 4. I have NOT ever been served with a notice of bankruptcy, made or discharged as a bankrupt; or has had my registration as a public accountant suspended or cancelled under Part V or Part VI of the Accountants Act (if applicable); or convicted of an offence in a court of law. Financial Interests 5. I, or my immediate family members (i) , do not hold any financial interests other than those described in the Declaration of Financial Interests Holdings Form (Annex A-2). I will ensure that any restricted financial interests as advised by PwC either held by myself or my immediate family members, will be disposed of prior to commencement of my employment with PwC Singapore. I understand that if I am in a managerial role and upon joining the firm, I will be required to record financial interests held by myself and my immediate family members into PwC’s Independence Checkpoint System, with the exception of those disposed of prior to commencement of my employment with the firm. Section 1 Section 2 (only for Client Service, Risk and Quality, and General Counsel staff) Yes No, not applicable Yes No If no, provide details: __________________________________________ Is Annex A-2 form attached? Yes No, not applicable Other Employment/Business Interest 1. (a) I understand that I may not serve as a director, an officer or in any executive or non-executive position of influence of companies or other organisations (including family-owned business, charitable/non-profit organisations, school alumni, religious organisations, resident committees, MCST, etc) without prior approval of the firm.

Transcript of Annex A Independence and Other Declarations · 2020. 2. 10. · Annex A Independence and Other...

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Annex A

Independence and Other Declarations (non-CF Client Service Staff) Page 1 of 2

Independence and Other Declarations

These declaration forms are submitted in support of your employment contract. You are required to complete the applicable pages in typewritten format (by typing in the editable fields), and only e-signatures should be used.

I hereby confirm that:

(b) I do not hold any positions mentioned in Paragraph 1 (a) above and I am not engaged in other forms of remunerative employment, except for those described in the Other Employment/Business InterestApplication Form (Annex A-1).

Is Annex A-1 form attached?

(c) I will ensure that any other employment/business interest not approved by PwC will be relinquished prior to commencement of my employment with PwC Singapore.

Confidentiality/Insider Trading/Privacy Statement2. I agree to comply with all confidentiality obligations in relation to client and non-client information not

available to the public which may come into my possession during my employment with the firm. I further confirm that I will not exploit such information in any way. I understand that the firm and client information, including firm software, methodologies, and manuals, not available to the public, that are obtained as a resultof my employment or any services rendered by the firm, may not be disclosed to others, exploited in any way, or retained by me when I leave the firm. I acknowledge that I understand and consent to your use of my personal data in accordance with the Privacy Statement set out in this letter or as updated from time to time by notification from the firm.

IT Security Policy3. I have read and am aware of the importance of proper use of information technology (IT) in the firm (Annex

D). In accepting the employment offer, I agree to comply fully with the firm’s IT security policy at all times.

Bankruptcy4. I have NOT ever been served with a notice of bankruptcy, made or discharged as a bankrupt; or has had my

registration as a public accountant suspended or cancelled under Part V or Part VI of the Accountants Act (if applicable); or convicted of an offence in a court of law.

Financial Interests 5. I, or my immediate family members (i), do not hold any financial interests other than those described in the

Declaration of Financial Interests Holdings Form (Annex A-2). I will ensure that any restricted financial interests as advised by PwC either held by myself or my immediate family members, will be disposed of prior to commencement of my employment with PwC Singapore.

I understand that if I am in a managerial role and upon joining the firm, I will be required to record financial interests held by myself and my immediate family members into PwC’s Independence Checkpoint System, with the exception of those disposed of prior to commencement of my employment with the firm.

Section 1

Section 2 (only for Client Service, Risk and Quality, and General Counsel staff)

Yes No, not applicable

Yes No If no, provide details: __________________________________________

Is Annex A-2 form attached? Yes No, not applicable

Other Employment/Business Interest

1. (a) I understand that I may not serve as a director, an officer or in any executive or non-executive position of influence of companies or other organisations (including family-owned business, charitable/non-profitorganisations, school alumni, religious organisations, resident committees, MCST, etc) without prior approval of the firm.

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Annex A

Independence and Other Declarations (non-CF Client Service Staff) Page 2 of 2

Other Financial Arrangements

(i) I am acting as an executor or trustee of an estate or trust.

Yes No

(ii) I am a beneficiary of an estate or trust.

Yes No

Note: We may contact you in due course for additional information if your answer is “Yes” to any of the above

questions.

Quality Reviews or Other Investigations 6. I agree to cooperate fully with any request for information or other assistance made by the firm or regulatory

authorities in connection with any quality review programmes or other investigations conducted by the firmor regulatory authorities (whether local or foreign). in respect of my conduct or work performed by me during my employment with the firm.

Below clause is applicable for those who provide audit services to an SEC issuer client or its affiliates: I consent to cooperate in and comply with any request for testimony or production of documents made by the Public Company Accounting Oversight Board in furtherance of its authority and responsibilities under the Sarbanes-Oxley Act of 2002. I understand and agree that this consent is a condition of my continued employment by or other association with the firm.

Independence Confirmation 7. I have read and understood the Guide to PwC Singapore Independence Requirements (Annex C) and I will

comply with the independence requirements during my employment with the firm. I understand that as I ama practice staff member, certain requirements of the policy may extend to my immediate family members (i) and I will ensure that they will also comply with the policy, to the extent that it applies to them, during my employment with the firm.

Personal Independence Compliance Testing (“PICT”) 8. I understand that as part of my employment with the firm, I am eligible to be selected for an independence

audit as part of the firm’s PICT programme and am required to retain records of my financial arrangements (including those of my immediate family members) for this purpose. Such records may include the following:- Income tax return - Brokerage, Fund Provider and Investment Statements - Insurance policies - Bank statements - Loan and credit card statements - Trust and estate information - Pension policies, employee benefit plans, superannuation funds - Documents should be retained from the time of joining the firm and thereafter kept for a period of at least

6 months

In the event that I am selected for the PICT, I agree to extend my fullest cooperation to the firm, including but not limited to, providing all necessary information and supporting documents that would be required for the audit.

Definitions: (i) An “immediate family member” in relation to a Partner or practice staff member (as defined under PwC Singapore Independence

Policy section 2.1-0) is: (a) The person's spouse, spouse equivalent (b) All dependent children, including stepchildren (c) Any other relative who receives substantial financial support from the Partner or practice staff member and over whom

significant influence is exercised.

Legal Name (As per NRIC/ Passport)

SignatureNRIC/ Passport No. Date

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Last revision date: 20 Nov 2019 | Form Ref No: HRM 2.7

Other Employment/Business Interest Application Form(To be completed only if you have other employment/business interests. Else, leave this page empty.)

Annex A-1

Note: If you are a full-time staff, you are not permitted to engage in other remunerative employment, business, company or concern. PwC may consider permission only under extenuating circumstances.

Section A – Staff Particulars Legal Name (As per NRIC/ Passport): LOS/BU: Position:

Full-time Part-time

I have other Employment/Business Interest: Yes (To complete Section B & C) No (To complete Section C)

Section B - Details Of Other Employment/Business InterestCompany Name and/or Name of Employer

Effective date of other employment &/or business interest Position held interest (e.g. Directorship, Shareholder,etc)

Please state if this is PwC client or non-client PwC Client Non PwC Client

Describe primary activity of the organisation/ entity

My work duration & if remunerated No of hours per week: No of hours per month: Remuneration:

Brief description of your role and any other comments:

Section C – Confirmation And Undertaking By Staff I confirm that the information provided above is correct and true and agree to advise PwC immediately should there be any changes to the information. In addition, I also undertake that: 1)The nature of the business activities or operations will not conflict with the interests of PwC.2)The additional work or business commitment will not interfere with my ability to fully discharge my

responsibilities and duties; including working overtime if needed.3)I agree that the information I have declared may be shared with other members of PwC for work-related /

business development reasons.

Signature NRIC/Passport No. Date Section D – For Official Use onlyBU Leader/ HOD Support BU Leader/ HOD

Supported

Not-supported (please state reasons below)

Name Signature Date

For Executive Appointments For Other Business Interests

Any risk management/independence concerns? Yes No

Directorship and Other Executive appointments: Approved Not Approved (please state reasons)

Independence Partner name Signature Date

Approved Not Approved (please state reasons)

HC Partner name Signature Date

Approved Not Approved (please state reasons)

HC Partner name Signature Date

Any risk management/independence concerns?

Independence Partner name Signature Date [For HC Partner Action] Mark to Head, M&C for notation Yes No

Comments/ Reason for rejection (if any)

Yes No

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Declaration of Financial Interests Holdings (To be completed only if you have Financial Interests Holdings. Else, leave this page empty.)

Annex A-2

I have Financial Interest(s) to declare Yes No

# Please refer to this link for list of ISIN codes for stocks listed on SGX http://www.sgx.com/wps/portal/sgxweb/home/company_disclosure/isin_code_download

Shares/ Bonds/Unit trusts/Funds Please provide full name of the issuer

#Identifier Security code e.g. ISIN, SEDOL, CINS

Ownership Please indicate self, spouse or dependent

Investment-linked insurance policies Please provide name of Insurer and underlying fund(s)

#Identifier Security code e.g. ISIN, SEDOL, CINS

Ownership Please indicate self, spouse or dependent

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Pension/Superannuation plans Please provide full name of entity that the pension arrangement is with and the name(s) of the underlying funds of the plan

#Identifier Security code e.g. ISIN, SEDOL, CINS

Ownership Please indicate self, spouse or dependent

Others e.g. CPFIS, employee stock options, options, warrants, debentures, etc.

#Identifier Security code e.g. ISIN, SEDOL, CINS

Ownership Please indicate self, spouse or dependent

I confirm that the above declaration is exhaustive and accurate and commit to comply with the disposals and information updates as required by PwC’s Singapore Independence Policy.

Number of pages used for this declaration: (please use as many pages as required)

Legal Name (As per NRIC/ Passport)

SignatureNRIC/ Passport No. Date

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Annex A-3

G Suite Business Rules applicable to PwC Singapore and PwC

Myanmar

G Suite is PwC’s primary office application. You must acknowledge that you have read and agreed to

the following rules and guidance as part of the conditions for your employment. The firm may

update those rules from time to time.

Business rules are crucial because infringement of regulatory obligations have criminal

consequences

While PwC global Network Information Security (NIS) has qualified G Suite for the highest

confidentiality classification, all PwC network firms must comply with a set of global business rules

governing the use of G Suite, including the use of Lotus Notes in certain conditions. Additional

business rules are required in Singapore and Myanmar to comply with the Official Secrets Act of

Singapore and Official Secrets Act of Myanmar (OSA), the Banking Act of Singapore and the Financial

Institutions Law 2016 of Myanmar.

The “SG & MM G Suite Business Rules” detailed here combine the global business rules and the

regulatory requirements specific to Singapore and Myanmar.

Infringement of the secrecy obligations are criminal offences punishable by fines and imprisonment:

● Official Secrets Act (Singapore)

The penalty for infringing the secrecy obligations in the Official Secrets Act of Singapore is a

fine up to SGD 2,000 and/or imprisonment up to 2 years.

● Official Secrets Act (Myanmar)

The penalty for infringing the secrecy obligations in the Official Secrets Act of Myanmar is

imprisonment up to 3 to 14 years.

● Banking Act (Singapore)

The penalty for infringing the secrecy obligations in the Banking Act is a fine up to

SGD 250,000 and/or imprisonment up to 3 years.

1. All engagements with Restricted clients

For all engagements with Restricted clients referring to any of:

(i) clients belonging to a group which Ultimate Parent is on the Global Google Exception Client

Registry;(ii) clients belonging to a group which Ultimate Parent by effective control is incorporated in China.

● As Client Lead Partner/ Engagement Leader or Engagement Manager, you must ensure that

the restriction is indicated both in the iPower client form and in the afFirm engagement

questionnaire; and you are responsible for reminding the engagement team of the restrictions;

● You MUST NOT use any of the G Suite applications;

● You must use Lotus Notes mail (Notes), whether the addressee is PwC internal or external.

You must start all emails internal and external in Notes and ensure that the email is marked

“This message will remain in Notes” (You will see this only after 23 September 2019 - refer to

the screenshot below).

G Suite Business Rules applicable to PwC Singapore and PwC Myanmar Page 1

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Annex A-3

 

 

2. OSA-restricted jobs

All jobs with ministries, statutory boards and other governmental agencies of Singapore (entities with

url ending with "gov.sg") and of Myanmar, as well as all jobs for Temasek Holdings Private Limited

(Temasek), GIC Private Limited (GIC) and Defence Science Organisation (DSO) are covered under the

Official Secrets Act of Singapore and the Official Secrets Act of Myanmar respectively. In some

occasions, for certain non-governmental entities, PwC Singapore and PwC Myanmar may agree to OSA

undertakings for engagements. Such engagements are collectively considered “OSA-restricted jobs”.

When using G Suite,

● Gmail: (1) You must NOT include information covered under OSA (“sensitive information”) in

the BODY of the email, and (2) you must encrypt all attachments containing sensitive

information sent via Gmail.

The restriction also applies to communication with PwC colleagues within our Firm and

network on such matters.

● Passwords must be agreed upfront with the clients and logged within LOS-designated

depository (eg work paper in the archival system of your unit i.e. Aura, iManage (DMS),

Maps).

● You must seek understanding from clients by notifying them of our use of third party IT

service providers and advise them to encrypt sensitive information or contact us for alternative

secure means of sending sensitive information. This notification to the client should be made

via use of RM-endorsed guidance as provided in this (ink)

● Passwords agreed between the engagement team and the clients must NOT be sent via Gmail

● Shared Drives: You must not use Google Drive for OSA-restricted jobs.

It is the responsibility of the Client Lead Partner/ Engagement Leader or Engagement Manager to

correctly complete the afFirm questionnaire with regards to OSA-restriction and to brief the

engagement team on the applicable business rules for OSA-restricted jobs.

3. Bank Customer Information

Bank Customer Information generally refers to

- for Singapore: any information, communicated to us by or on behalf of our bank client,

relating to the account of the bank's customer and identifying the customer, as defined in the

Banking Act Section 40A and restricted in Section 47.- for Myanmar: the affairs, records and transactions of a customer of a bank under the Financial

Institutions Law 2016

When using G Suite,

● Gmail: (1) you must NOT include Bank Customer Information in the BODY of the email, and

(2) you must encrypt all attachments containing Bank Customer Information sent via Gmail.

The restriction also applies to communication with PwC colleagues within our Firm and

network on such matters.

G Suite Business Rules applicable to PwC Singapore and PwC Myanmar Page 2

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Annex A-3

 

● Passwords must be agreed upfront with the clients and logged within LOS-designated

depository eg work paper in the archival system of your unit such as Aura, iManage (DMS),

Maps.

● Passwords agreed between the engagement team and the clients must NOT be sent via Gmail

● Shared Drives: You must encrypt (password protect or WinZip password) all files containing

Bank Customer Information.

4. Archiving of documents and data from client work

The standard policy on archival of documents and data as set forth in the policy applies to G Suite.

● For Assurance: You must comply with the inform.sg guidelines.

● For Tax: You must continue using iManage (DMS). Do not retain any engagement file in

Google Drive.

● For Advisory: You must refer to the practice of your BU.

When using Google Drive, all engagement files must be stored only on the shared drive dedicated to

this engagement. At the end of the engagement, you must delete the dedicated Shared Drive.

5. PwC China/ Hong Kong

All communications with PwC China/ Hong Kong concerning client engagement matters must use

Lotus Notes (mail) only: you must start all emails in Notes and ensure that the email is marked “This

message will remain in Notes”.

For purely internal matters, the restriction does not apply to communication with PwC China/ Hong

Kong colleagues. You may use Gmail, Google Calendar and Meet with Partners and staff in PwC

China/ Hong Kong for matters that are not client-confidential.

6. Google Acceptable Use Policy

You MUST READ and COMPLY with the Google Acceptable Use Policy (Link). GOOGLE reserves the

right to suspend your account in case of violation (e.g. mass mailing).

I agree to the G Suite Business Rules applicable to PwC Singapore and PwC Myanmar.

G Suite Business Rules applicable to PwC Singapore and PwC Myanmar Page 3

Legal Name (As per NRIC/ Passport)

SignatureNRIC/ Passport No. Date