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Building trust
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Non-financial assurance
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Interaction with stakeholders
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Welcome
A year in review
Governance
Audit quality
People
Technology
Ethics
Appendices
Building trust

In the market we are seeing a rise in ethical 
consumerism and investors increasingly looking 
beyond the numbers – to climate, biodiversity, 
social impact and purpose. And information on 
regulation, technology and ESG play an 
important role in helping stakeholders to 
understand full enterprise value.
In response to this changing environment we are 
seeing a reporting and regulatory revolution. 
Companies are expanding their reporting to 
meet the increased demand for more 
information and more complex reporting 
requirements, creating a gap between the 
information organisations report and what is 
assured. 
We will continue to invest in our people, skills 
and technology to bridge that gap and address 
the demand for independent, robust assurance 
over non-financial information that is in the 
public interest.
More information on how we provide assurance 
over ESG, regulatory, third party and other non-
financial reporting can be found on our Non-
financial assurance page1.
A focus on climate change
Over the past few years, we have 
heard requests from the investment 
community to provide additional 
transparency in our audit reports, 
particularly about whether, and how 
material climate risk exposure has 
been assessed and factored into 
our audit process, where relevant. 
This has been further outlined in  
our ‘Interaction with stakeholders’ 
section on page 114. 
Assurance over climate related 
information
Carbon and climate change performance data 
is a key part of non-financial reporting, where 
investors and other stakeholders demand 
reporting they can trust. Existing reporting 
frameworks such as Streamlined Energy & 
Carbon Reporting (SECR) and the Taskforce 
on Climate related Financial Disclosures 
(TCFD) already require disclosure of carbon 
emissions and other climate related metrics. 
Further reporting frameworks worldwide 
require the same. 
Our recent analysis of TCFD reports2 shows 
that organisations now disclose up to 16 
metrics under the metrics and targets pillar  
to demonstrate how they are measuring and 
managing climate change. 80% of companies 
reported a carbon reduction related measure 
linked to executive remuneration. It is 
therefore more important than ever that this 
data is accurate and can be relied upon. 
Critically, accurate carbon emissions data 
informs an accurate carbon reduction strategy 
and pathway to Net Zero. Reliable data is 
needed for accurate decision making as well 
as satisfying stakeholder needs, including 
employee engagement.
1 Source: www.pwc.co.uk/services/audit/non-financial-assurance.html
2 Source: www.pwc.co.uk/audit/assets/pdf/review-of-year-two-tcfd-reporting.pdf 
The future of audit
Organisations are now being 
judged on more than just financial 
performance. In a complex 
world that is changing at pace 
stakeholders are looking to 
businesses for information  
they can trust.
Non-financial assurance
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Third-party assurance
Service providers are judged on more than  
just the services they provide. Customers of 
service providers are exposed to a broader set 
of risks such as IT resilience, cyber attacks,  
data loss, ethical sourcing, potential use of  
slave labour, and compliance. Customers are 
demanding greater transparency on how  
service providers are managing these risks.
•	 Financial services businesses, from assuring 
platforms for asset and wealth management, 
clearing, settlement and exchange,  
to performing reviews of various controls 
reports (SOC1, SOC2, ISAE3402 and AAF).
•	 IT systems and platforms, including 
assurance over market infrastructure, 
eCommerce, fulfilment and logistics 
platforms.
•	 Critical business systems, such as payment 
infrastructure and payroll systems.
•	 Cybersecurity systems, assuring resilience, 
privacy and security controls.
•	 Emerging risks, such as blockchain 
assurance and cryptocurrency. 
•	 Supply chain, covering service levels, 
sustainability and regulatory/legal 
commitments.
Regulatory assurance
Client assets and money. For authorised 
investment firms, we scrutinise the 
processes and controls that are being 
operated to ensure their clients’ funds  
are being adequately segregated from  
their own.
Benchmarks and indices. Testing policies, 
processes and controls to make sure 
organisations produce indices transparently 
and in accordance with their methodologies; 
avoid conflicts of interest; and play their part 
in protecting customers and investors.
Safeguarding. For authorised payment 
institutions (PI) and electronic money 
institutions (EMI), we scrutinise their ability  
to protect customers’ funds.
Prudential reporting. Risk-weighted assets 
(RWA) Assurance. Scrutinising the reporting 
provided to regulators, to assess for 
compliance with prudential requirements.
Data privacy. Subjecting processes and 
controls of organisations to rigorous testing, 
so regulators can be confident that personal 
data and sensitive information has been 
adequately controlled and protected.
Emerging assurance
As new and emerging 
business areas demand 
scrutiny, we build assurance 
models to effectively 
scrutinise and challenge the 
data, metrics and controls 
that are being established. 
When these areas need 
specific expertise – such as 
blockchain and cybersecurity 
or emissions and offsets –  
we engage subject matter 
experts from across the firm, 
bringing industry or technical 
knowledge to help us design 
the right assurance 
approach.
ESG assurance
Sustainability and carbon reporting.  
Making sure that the reports of the organisations  
we audit stand up to rigorous scrutiny. This is about 
more than just data – it’s about challenging the 
measures and context they’re using to tell the story 
of their progress and ensuring compliance with the 
relevant reporting standards.
Diversity and inclusion reporting.  
From reporting on gender pay to equal employment 
opportunities, stakeholders expect organisations to 
be creating an equitable, inclusive and progressive 
workplace. We make sure the organisations we 
audit can stand behind this information.
Social impact reporting. Providing assurance over 
how companies are measuring the positive impacts 
their actions are having on society.
Supply chain management reporting. Providing 
assurance that organisations understand and 
control their supply chains. From health and safety 
data to waste and water usage.
Green, social and sustainable financing. 
Checking that investors' funds are deployed in the 
manner intended.
Corporate governance. Making sure that 
companies have adequate processes and controls 
over the governance considerations that matter 
most to their stakeholders – and that those 
processes and controls are working as intended.
A summary of the non-financial services currently being delivered from our Audit Line of Service, in line with the FRC ethical standard for 
permissible work, are outlined below. 
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PwC | UK Transparency Report 2023
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To build trust in the progress 
Unilever is making towards its 
sustainability performance goals, 
PwC UK works to independently 
assure its annual reporting. 
Setting the scene
In 2020, Unilever launched its fully 
integrated corporate strategy called 
Compass. Central to this strategy is  
its ambition to be the global leader in 
sustainable business, and it has put  
in place company-wide sustainability 
commitments for all of its brands, as  
well as a set of performance measures 
reported annually to track progress. 
While it’s not currently mandatory for 
companies to have their non-financial 
reporting externally assured, Unilever 
wants its customers, employees and 
investors to have confidence in the 
progress they are making, and asked  
PwC to independently verify the  
accuracy of the sustainability data 
generated across its global operations. 
How we helped
Unilever is one the world's largest consumer 
goods companies, employing 127,000 people 
and operating 400 brand names in over 190 
countries. While providing assurance for a 
company of this size can often prove 
challenging, when combined with the broad 
scope of sustainability performance 
measures Unilever tasked us with assuring, 
this year was particularly complex. 
We worked to assure measures ranging from 
the amount of their ice cream products sold 
that meet WHO-aligned nutritional standards, 
to the amount of reusable plastic in their 
packaging. We assessed the amount of 
hazardous waste being generated in a 
number of their production facilities, through 
to the percentage change in greenhouse gas 
emissions from energy and refrigerant use 
across their operations. And, with support 
from colleagues across our global network, 
we conducted a combination of virtual and  
in person site audits of different Unilever 
production processes around the world 
including: ice cream in America; laundry 
detergent in Brazil; soap in Indonesia; and 
skin cleanser in South Africa. 
Case study: Building trust in Unilever’s global sustainability reporting
By attending these sites, either in person 
or remotely, we were able to test the 
integrity of data that Unilever reported, 
challenging the methodologies used to 
provide an accurate picture of its 
sustainability reporting. 
Making a difference
Having conducted the site visits, and 
tested the performance, we were then 
able to produce our report for Unilever 
confirming the progress it is making in  
the various areas we assured. This report, 
when combined with the ones we have 
previously produced, demonstrates to 
Unilever’s customers, employees, 
investors and other stakeholders the 
impact that efforts to improve the 
business’ sustainability is having. 
As concerns over the level of corporate 
‘greenwashing’ continue to grow, this 
type of regular independent assurance 
can help to build real confidence that 
companies are being transparent in  
their reporting and living up to their 
commitments.
“Sustainability matters are increasingly 
important for all businesses, and 
critical to their success. At Unilever, 
we committed some time ago to report 
on sustainability performance across 
our business and, where possible, 
our extended value chain, and PwC’s 
independent assurance has been 
crucial to building confidence in the 
progress we’re making.” 
Lysanne Gray  Executive Vice President, Sustainable 
Business, Unilever
13
Our role
Featuring
Outcome
We attended 13 Unilever premises 
in eleven countries to assess their 
sustainability progress.
Testing data to provide an 
accurate picture of Unilever's 
sustainability reporting.
Independently assessing  
a variety of performance 
measures in diverse locations.
Greater confidence in the 
transparency and accuracy of 
Unilever’s sustainability reporting.
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PwC | UK Transparency Report 2023
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PwC is proud to audit some of the 
UK’s most iconic charities, helping 
ensure transparency and reliability 
is at the heart of the country’s  
most purposeful organisations.
Setting the scene
Whether securing safe water at 
WaterAid, supporting seriously ill 
young people at Great Ormond  
Street Hospital Children’s Charity,  
or providing first aid and emergency 
medical services at St John 
Ambulance, all the charitable 
organisations we audit deliver 
solutions to some of society’s most 
important problems every day. 
Charities comply with the same 
standards and scrutiny during an  
audit as other companies but because 
they interact with some stakeholders 
differently – people donate money  
to support causes they care about, 
instead of investing for financial return 
– there is an additional lens of scrutiny.
How we helped
As societies grapple with a myriad of 
challenges, millions of people continue  
to rely on the vital work of charities.
But these organisations face challenges  
of their own. Donors, trustees and 
regulators want assurance that funds are 
being used as intended. They want to 
know that risk management and strong 
internal controls are driving the best 
possible outcomes while providing for  
a sustainable future. This includes 
compliance with the Charity Governance 
Code. On top of this, charities face the 
same rising expectation of transparency 
around environment, social and 
governance (ESG) issues. 
All of the above is considered by our 
charity sector audit team. The audit 
opinion underpins confidence in the 
financial information presented in the 
annual report and accounts. Our audit 
teams are also in a unique position to  
give independent feedback on the  
internal control environment. 
Case study: Building trust in the charity sector through audit
We encourage the charities we audit to invest  
in good practice reporting, particularly through 
the Charities Award, part of our annual Building 
Public Trust Awards, and our annual reporting 
workshop. Charities Audit Leader Daniel Chan 
MBE explains: “The ‘S’ in ESG is what charities 
inherently do, so this represents an opportunity 
for the sector to set an example on important 
non-financial disclosures in this area.” 
Running a charity requires specialist skills.  
We help foster networks through regular events 
for Finance Directors, CFOs and Trustees, in 
particular Audit Committee members of larger 
charities.
Making a difference
Among the iconic charities we audit are 
Charities Aid Foundation, Cancer Research  
UK, Great Ormond Street Hospital Children's 
Charity, Macmillan Cancer Support, MSI 
Reproductive Choices, The Royal National 
Theatre, Plan International, St John  
Ambulance, The Prince’s Trust, and WaterAid.
Our people use technology and sector expertise 
to scrutinise the inner workings of charities, 
providing independent reasonable assurance 
that the financial statements are reliable. 
“Compliance and governance are 
critical to us as a charity, being 
responsible for the stewardship of our 
donors' money. Requirements continue 
to increase and having the support 
of PwC and their skills in audit and 
assurance is extremely valuable to us  
in ensuring high quality reporting.”
Kevin Thompson  Trustee and Chair of Finance & 
Resources Committee, Great Ormond Street Hospital 
Children’s Charity
5
PwC UK audits five of the top 20 
most famous charities in the UK
Our auditors underline 
trust in the charity sector
Some of the UK’s best 
known charities
A sustainable future for 
the UK's charity sector
We also review a charity’s response to 
additional requirements, including how  
they report on their fundraising activities. 
Our clients tell us they find our insights  
and benchmarking useful, including 
visualisations from technology tools  
which identify trends in their activities.
By providing an independent opinion we 
help charities build and maintain trust with 
their stakeholders, supporting the wider 
sector in its long term goals to solve some 
of society’s most important problems.
Outcome
Featuring
Our role
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Interaction with stakeholders
Investor engagement
We have a dedicated team that works with 
shareholders and other members of the 
investment community, including asset 
owners, asset managers, analysts, corporate 
governance and stewardship professionals, 
proxy advisers and credit ratings agencies.
Through this engagement we listen to the 
views of stakeholders on a range of 
reporting, regulatory and governance issues 
facing UK companies, as well as hear their 
thoughts on assurance matters and the role 
of the audit profession in their work. This 
dialogue ensures that we understand the 
needs and expectations of investors. This 
enables us to help our client engagement 
teams, as well as our clients’ executive and 
non-executive directors, to better respond  
to shareholder needs.
Some highlights of our stakeholder engagement 
team’s work this year include the following:
Investor-focused events and publications
We engage with institutional investors, retail 
investors and analysts throughout the year  
on relevant and topical issues. These 
engagements cover a variety of themes 
including implementing major new accounting 
standards, tax reporting, audit reform, political 
developments, and climate reporting. Over the 
course of FY23, we sought investor input into 
multiple PwC research reports and publications, 
including the firmwide campaign ‘Rethink 
Resilience’, the Purpose of Work Survey and  
our Materiality Matrix. You can view our current 
material issues on our website1.
As part of our ongoing work to understand 
the views of the investment community, 
PwC conducted a global investor survey in 
September 2022. A UK cut of the survey2 
was issued in February 2023, with 99 
investment professionals focused on the 
UK market responding to the online survey, 
which was in tandem with in-depth 
conversations. The UK survey explored 
investors' views on how well they thought 
organisations are addressing the ESG 
issues they face; how companies are 
delivering their top priorities; and, the role 
of the audit and high quality information in 
building trust. 
1 Source: https://www.pwc.co.uk/who-we-are/our-
purpose/strategy/materiality.html
2 Source: https://www.pwc.co.uk/issues/esg/investors-
demand-greater-clarity-on-esg-data-how-can-
businesses-keep-up.html
To a very large 
extent 23%
Don’t know 9%
Not at all 2%
To a limited 
extent 9%
To a large 
extent 27%
To a moderate 
extent 29%
% of respondents who think corporate reporting contains unsupported 
claims about a company’s sustainability performance to this extent
We also hosted investors at PwC’s Building 
Public Trust Awards and the Trust and 
Transparency Forum 2022. Based on our 
regular dialogue with investors on the topics 
most important to them, we have reset and 
refreshed our investor events agenda to 
ensure it meets investor demands for 
information, including how companies can 
evolve for disruption, cybersecurity and 
supply chain issues. The first event of the 
new programme took place in July 2023.
89%
of respondents who 
invest in the UK suspect 
corporate disclosures still 
contain some 
greenwashing
74%
of UK investors say independent 
reasonable assurance opinion gives 
them confidence in the accuracy of  
a company’s sustainability reporting.
"If there is assurance on 
sustainability reporting, I think the 
purpose should be the same as the 
audit of the financial statements to 
that the reader can be comfortable 
that what’s reported is reasonably 
accurate and relevant."
UK based investor
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From a policy perspective, below are some  
of the actions we have taken in recent years: 
•	 mandatory consideration of  
climate related risks in all audits; and
•	 policy requiring specific reference  
to our audit work on climate in our  
FTSE 350 audit opinions.
For premium listed companies there are 
mandated climate related disclosures, and 
other businesses are now also choosing to 
include climate related statements in their 
reporting. With more regulation on the 
horizon, businesses must navigate their way 
through layers of complexity in order to 
ensure clarity and transparency. 
The Spring Report
In autumn 2022 the Audit Committee  
Chairs’ Independent Forum (ACCIF) brought 
together a group of experienced audit 
committee chairs, auditors, and executives 
from the FRC with the objective of further 
enhancing audit quality. The group met a 
number of times over the course of several 
months and discussed a range of different 
aspects of audit quality. The output from 
these discussions was ACCIF’s Spring 
Report2 which was published in June 2023. 
The report includes key learnings from the 
discussions and the next steps that ACCIF, 
the FRC and the audit firms that participated 
agreed to take to share the learnings and put 
them into practice. 
PwC participated in the project and we  
have already taken a number of actions in 
response to the commitment we made to 
share the learnings of the project, with 
further engagement planned. The project 
reaffirmed to us the benefits of engagement 
between key stakeholders across the 
ecosystem we work in and we look forward 
to further opportunities to engage with all 
stakeholders on this important topic.
Corporate Reporting Users’  
Forum (CRUF)
PwC continues to provide secretariat 
support to the CRUF in the UK and across 
their global network. As secretariat, we 
provide administrative support for meetings, 
liaise with standard setters and regulators to 
facilitate the submission of comment letters, 
and provide assistance on technical points 
when requested. This year we have 
continued to help the CRUF raise awareness 
of the group and their views on reporting.
Ongoing dialogue between  
the investment community and  
senior partners
We met with shareholders, analysts and 
proxy advisers across a number of sector 
specialisms through one-on-one meetings  
to discuss various topics, including audit 
reform, sustainability-related matters, 
including climate reporting, and accounting 
standards. The strong relationships and 
open dialogue we have with the investment 
community enable high quality engagement 
on a range of topics of mutual interest.
1 Source: https://www.pwc.co.uk/ceo-survey.html
2 Source: https://accif.co.uk/ACCIF%20-%20
The%20Spring%20Report%20-%20full%20
Report%20June%202023.pdf
Communicating with our  
Public Interest Body (PIB)
The feedback and insight received from our 
investor engagement activities informs the 
regular updates provided to our governing 
bodies, including our PIB. Over the last year, 
key topics such as corporate reporting and 
governance, climate risk in the financial 
statements, and audit transparency have 
been discussed with the investment 
community and included in the briefings 
provided to the PIB so that these topics can 
be discussed amongst the executives and 
Independent Non-Executives (INEs) at their 
regular meetings.
Trust and Transparency Forum 
We actively invite members of the investment 
community, alongside audit committee 
chairs, non-executive directors and other 
stakeholders, to our Trust and Transparency 
Forum. This forum was held in November 
2022 for the first time and is an important 
part of our commitment to transparency and 
building trust in our approach to audit. 
At the forum, guests had the opportunity  
to hear from our people including our 
leadership team on multiple topics, such as 
climate reporting, the use of technology, our 
commitment to audit quality and the future of 
audit and assurance. The second event will 
be held in autumn 2023.
Climate risk in the financial  
statements and audit
Investors and wider society are demanding 
that companies provide greater transparency 
on their emissions, more detail on their 
environmental strategies, and further insight 
into how climate change will impact their 
business in the future. Our 2022 CEO Survey1 
found that over 40% of CEOs say they will 
invest in decarbonising their business model 
this year and are investing in technology to 
support their ESG efforts. 
Climate risk has remained a critical area  
of audit focus over recent years and we’ve 
made significant strides in responding to the 
growing expectations of us in this area, 
including: 
•	 providing all of our qualified auditors with 
training on climate related risks and their 
impact on the statutory audit;
•	 encouraging the sharing of knowledge 
through our audit climate change industry 
networks; and 
•	 setting up a climate audit technical team  
to provide practical support to our people.
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Reporting to audit committees
When reporting to audit committees  
and those charged with governance in 
organisations where no audit committee 
exists, we place particular emphasis on 
communicating our audit scope and 
approach, together with our assessment  
of audit risk. During the course of the  
audit we communicate threats to auditor 
objectivity, including independence, the 
significant risks and judgements that 
impact the reported financial performance 
and position, and the manner in which  
the information is presented in the  
annual report.
This includes highlighting judgements 
made by management, in preparing the 
financial statements, that we believe are 
important to an understanding of the 
performance and position being presented. 
The nature of accounting and the need to 
make judgements and estimates means 
that there is often not a precise answer, 
and this is reflected in our reporting. It is 
also our role to inform the audit committee 
whether we can conclude that what is 
reported externally is true and fair within 
established norms of materiality, including 
considering both qualitative and 
quantitative aspects of accounting and 
reporting.
Audit Committee Network
The PwC Audit Committee Network 
supports audit committee chairs and 
members in an ever changing market 
landscape. The role of the Audit Committee 
is becoming more challenging due to 
increasing demands from regulation and an 
expanding risk environment. We offer a 
series of workshops designed for FTSE 350 
(and equivalent) audit committee chairs and 
members. Our workshops include updates 
on regulatory, accounting and corporate 
reporting developments, as well as other 
topics high on the Audit Committee agenda. 
Further information can be found here.1
External reporting
The form and content of our audit reports for 
UK entities are laid down by UK legislation 
and the FRC.
We are committed to making our reports 
clear and unambiguous. Enhanced audit 
reports provided to a range of organisations, 
including all listed entities, include 
descriptions of: how our audit was scoped; 
how we addressed the risks of material 
misstatement that we identified; and our 
application of materiality in determining the 
nature, timing and extent of our audit 
procedures; and evaluating the effect of 
misstatements. These enhanced audit 
reports provide us with the ability within our 
audit report to ‘tell the story of our audit’ in a 
meaningful and informative way to enhance 
users’ understanding of the financial 
statements. 
For UK Public Interest Entities as defined by 
the FRC Ethical Standard and company law 
the enhanced audit reports also include 
increased transparency on our 
independence including:
•	 a declaration that the non-audit services 
prohibited by the FRC’s Ethical Standard 
were not provided and that the firm 
remained independent of the entity in 
conducting the audit;
•	 an indication of any services, in addition 
to the audit, which were provided by the 
firm to the entity and its controlled 
undertaking(s) and which have not been 
disclosed in the annual report or financial 
statements; and
•	 disclosure of our period of tenure.
We welcome, fully support and embrace the 
moves towards greater transparency over 
the audit process that results from these 
enhanced audit reports. Sometimes it is 
necessary for us to modify our audit opinion, 
or to include details of a material uncertainty 
in respect of going concern. In such cases, 
engagement teams consult with others, 
including technical specialists, to help 
ensure that the modification/emphasis is 
warranted and that the audit report wording 
is clear. In addition to our audit report, in 
certain situations we also have reporting 
obligations to regulators and to other 
organisations specified by auditing 
standards, UK law and regulation, such as 
the Financial Conduct Authority and the 
Prudential Regulation Authority.
1 Source: https://www.pwc.co.uk/who-we-are/
the-leadership-exchange/the-audit-committee-
network.html
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Welcome
A year in review
Governance
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Building trust