Document Retention & Destruction Policy

Introduction

PMG Consulting (hereafter referred to as PMG) is an exclusively digital firm. This policy establishes the standards and procedures governing the retention, storage, and destruction of records created or received in connection with PMG's operations and client engagements. PMG's approach to document retention is built on three principles: client data is held for the shortest period necessary to fulfill PMG's obligations; PMG's own work product and intellectual property is retained indefinitely as a core organizational asset; and all records are managed with the integrity, security, and accountability that PMG's clients, personnel, and legal obligations require.
This policy applies globally. Regional business units and licensees may establish supplementary retention schedules where required by local law, provided those schedules meet or exceed the standards set out in this policy. Where local law requires a longer retention period than this policy prescribes, the local law standard applies.

Scope

This policy applies to all PMG personnel as defined in the Intellectual Property Policy, including employees, contractors, consultants, embedded leaders, and executives. It governs all records associated with client engagements and PMG's internal operations, whether created by PMG personnel or received from clients, third parties, or counterparties, and whether stored on PMG systems, cloud platforms, or any other digital medium.
Physical records should not exist within PMG's operations. Where a physical record comes into existence for any reason, it must be digitized and the physical copy securely destroyed as soon as reasonably practicable. Once digitized, the record is subject to this policy in the same manner as any other digital record.

Definitions

Term	Definition
Client Record:	Raw data provided by a client to PMG in connection with an engagement, and any data or document that contains materially sensitive information, personally identifying information, or information subject to intellectual property protection, trade secrets, or other categories of protected data, regardless of whether that information originated with the client or was derived from client data by PMG in the course of the engagement.
PMG Work Product:	Documents, deliverables, reports, analyses, case studies, methodology outputs, tools, templates, and any other materials prepared by PMG personnel in the course of an engagement or as part of PMG's internal operations, that do not contain Client Records as defined above or from which all Client Records have been removed or anonymized.
Financial Record:	Any record relating to a financial transaction, including expense submissions, invoices, vendor agreements, procurement records, payment records, and any other record required to be maintained under applicable financial reporting or tax obligations.
Anonymized Record:	A record from which all Client Records have been permanently removed or irreversibly de-identified such that no individual, organization, or protected data element can be identified or reconstructed from the remaining information.
Whistleblower Record:	Any record created in connection with a report, investigation, or outcome under PMG's Whistleblower & Speak-Up Policy, including the report itself, investigation notes, findings, and any correspondence related to the matter.
Retention Clock:	The date from which a retention period begins to run, as defined for each record category in Section 3.
Projects Team:	PMG's projects function, administered via projects@askpmg.com, which holds primary responsibility for administering this policy.

1. Guiding Principles

1.1 PMG is an exclusively digital firm. All records must be created, stored, and managed in digital form. Physical records have no place in PMG's standard operations and must be digitized and physically destroyed as soon as reasonably practicable upon receipt or creation.
1.2 Client Records are held for the shortest period necessary consistent with the defined retention schedule in Section 2 of this policy. PMG does not retain identifiable client data beyond what is required to fulfill its engagement obligations and meet its legal and financial record-keeping requirements. The retention periods specified in Section 2 represent the maximum period for which Client Records will be held before anonymization or destruction. After the applicable retention period, Client Records must be anonymized or destroyed in accordance with this policy.
1.3 PMG Work Product is retained indefinitely as part of PMG's intellectual property and methodology. Once Client Records have been removed or anonymized, the remaining work product belongs to PMG and may be retained, used, and built upon without restriction, consistent with the Intellectual Property Policy.
1.4 Anonymized or pseudo records of client engagements, meaning records from which all Client Records have been permanently removed or irreversibly de-identified, are retainable indefinitely and are not subject to any destruction obligation under this policy.
1.5 Internal PMG records that are not client-facing are subject to retention standards set at the team level. Each PMG team is responsible for establishing and maintaining its own retention schedule for internal records consistent with the principles of this policy. Regional licenses and business units may set their own document retention schedules as required by local law.

2. Record Categories and Retention Periods

The following table sets out the global retention standards applicable to each record category. All retention periods run from the Retention Clock applicable to that category as defined in Section 3.

Record Category	Retention Period	Post-Retention Action
Client Records	1 year from conclusion of engagement	Anonymize or destroy
Financial Records	7 years from the date of the relevant transaction	Destroy
PMG Work Product	Indefinite	No destruction obligation
Anonymized Records	Indefinite	No destruction obligation
Whistleblower Records	Indefinite	No destruction obligation
Physical Records	Digitize immediately, destroy physical copy as soon as reasonably practicable	N/A
Internal Team Records	As set by the relevant team	As set by the relevant team
Regional and Licensee Records	As required by local law, subject to global minimums	As required by local law

3. Retention Clocks

3.1 For Client Records, the retention clock starts from the date on which final payment is received by PMG under the applicable engagement. Where final payment has not been received within ninety (90) days of the contractually agreed payment date, the retention clock starts from that ninety-day mark regardless of whether payment has been received. This backstop prevents a client's failure to pay from extending PMG's data retention obligations indefinitely. The Projects Team must be notified by Finance of the date of final payment receipt, or of the expiry of the ninety-day backstop, so that the retention clock can be recorded accurately in the engagement register.
3.2 For Financial Records, the retention clock starts from the date of the relevant transaction, meaning the date the expense was incurred, the invoice was issued, or the payment was made, as applicable.
3.3 For PMG Work Product, no retention clock applies. PMG Work Product is retained indefinitely and is not subject to any scheduled destruction.
3.4 For Whistleblower Records, no retention clock applies. Whistleblower Records are retained indefinitely in recognition of PMG's absolute confidentiality obligations under the Whistleblower & Speak-Up Policy and the potential for related legal exposure to arise at any future time.
3.5 Where a record falls into more than one category, the longer retention period applies. For example, where a client engagement record also constitutes a Financial Record, the seven-year financial retention period governs and the one-year client data period does not shorten it.
3.6 Where a record is subject to a legal hold, meaning it is or may be relevant to actual or anticipated litigation, regulatory investigation, or legal obligation, the retention clock is suspended for the duration of the legal hold regardless of the category of the record. The Projects Team must be notified immediately when a legal hold is required, and PMG Legal is responsible for issuing and lifting legal holds.

4. Anonymization Standard

4.1 Where Client Records are anonymized rather than destroyed at the end of the retention period, the anonymization must be irreversible. Anonymization is sufficient only where no individual, organization, or protected data element can be identified or reconstructed from the remaining information by any reasonable means, including by reference to other information available to PMG or to a third party.
4.2 Pseudo-anonymization, meaning the replacement of identifying information with a code or reference that could be reversed, does not satisfy the anonymization standard in this policy unless the key required for reversal is permanently destroyed at the same time the anonymization is applied.
4.3 The Projects Team is responsible for ensuring that anonymization is applied correctly and completely before any anonymized record is retained beyond the applicable retention period. Where the Projects Team is uncertain whether a record has been adequately anonymized, PMG Legal must be consulted before the record is retained.
4.4 Once a record has been anonymized in accordance with this section, it is classified as an Anonymized Record and is retainable indefinitely as part of PMG's institutional knowledge and methodology assets.
4.5 The incidental or de minimis inclusion of an identifiable name, title, or other personal reference in an archived internal document does not constitute a material breach of the anonymization standard in this policy, provided that all of the following conditions are met:

1. The document has been reviewed in good faith for Client Records and any material identifying information has been removed or de-identified in accordance with Sections 4.1 and 4.2;
2. The residual identifying information is genuinely incidental, meaning it appears in passing rather than as substantive content, and its presence does not allow a reader to reconstruct any Client Record as defined in this policy;
3. The document is classified as internal access only and is stored on a PMG-approved platform with access controls restricting it to authorized PMG personnel;
4. The incidental inclusion is not the result of a deliberate decision to retain identifying information that should have been removed.

Where these conditions are met, the document may be retained as PMG Work Product without further anonymization action. Where there is any doubt as to whether an inclusion is genuinely incidental or material, the Projects Team must treat it as material and apply full anonymization or consult Outside Counsel before retaining the document.

5. Destruction Standard

5.1 PMG requires secure permanent deletion of all records that have reached the end of their applicable retention period and are not being anonymized for continued retention. Secure permanent deletion means deletion by a method that renders the data unrecoverable by any reasonable technical means.
5.2 For cloud-stored records, secure deletion must comply with the deletion standards of the relevant platform. Where a platform's standard deletion process does not constitute secure permanent deletion, the Projects Team must use an alternative deletion method or engage a qualified third party to perform the deletion.
5.3 For physical records that have been digitized, physical destruction must be carried out by shredding, incineration, or another method that renders the physical record unreadable and unrecoverable. Physical destruction must occur as soon as reasonably practicable following digitization.
5.4 No audit trail or destruction certificate is required following secure deletion. The act of deletion in accordance with this policy is sufficient.
5.5 Destruction must not be carried out in respect of any record subject to a legal hold. Where a scheduled destruction date falls during a legal hold period, destruction is suspended until the legal hold is lifted by PMG Legal.
5.6 The destruction obligations in this section apply to records as defined in this policy. They do not extend to system-level metadata, administrative audit logs, or platform-generated access logs created by PMG's digital infrastructure, including Google Workspace Admin Audit Logs and any equivalent logging generated by other PMG-approved platforms. Such logs are governed exclusively by PMG's Information Security Policy and the default retention architecture of the relevant platform. PMG makes no representation that the destruction of a record results in the purging of associated system-level logs, and clients and personnel should not interpret record destruction under this policy as encompassing the elimination of platform-generated access or activity data.

6. Storage and Security Standards

6.1 All records retained under this policy must be stored on PMG-approved digital platforms in accordance with PMG's Information Security Policy. Records may not be stored on personal devices, personal cloud accounts, or any platform not approved by PMG for business use.
6.2 Access to retained records must be limited on a need-to-know basis. The Projects Team is responsible for ensuring that access controls are applied appropriately to records in its custody, and that access is reviewed and updated when personnel leave an engagement or depart PMG.
6.3 Whistleblower Records must be stored with access restricted exclusively to the Ethics Officer and such other persons as the Ethics Officer determines are necessary, consistent with the confidentiality obligations in the Whistleblower & Speak-Up Policy. The Projects Team may not access Whistleblower Records without the express authorization of the Ethics Officer.
6.4 Financial Records must be stored in a manner that allows Finance to retrieve and produce them within a reasonable time in response to an audit, regulatory request, or legal obligation. Finance is responsible for the storage and accessibility of Financial Records within its custody, in coordination with the Projects Team.

7. Physical Records

7.1 PMG operates as an exclusively digital firm. The receipt or creation of physical records is not a standard part of PMG's operations and should be avoided wherever possible.
7.2 Where a physical record comes into existence, the responsible PMG personnel member must digitize it as soon as reasonably practicable. The digitized version must be stored in accordance with this policy from the date of digitization.
7.3 Following successful digitization, the physical record must be securely destroyed without delay. Secure destruction of physical records means shredding, incineration, or an equivalent method that renders the record permanently unreadable.
7.4 Where a physical record contains Client Records, personally identifying information, or any other sensitive data, physical destruction must occur on the same business day as digitization where reasonably practicable, and must not be deferred beyond five business days from digitization under any circumstances.

8. Responsibilities

8.1 The Projects Team, administered via projects@askpmg.com, is the primary administrator of this policy. The Projects Team is responsible for:

1. Maintaining an accurate register of active and concluded client engagements and their applicable retention clocks;
2. Ensuring that Client Records are anonymized or destroyed in accordance with the retention schedule in Section 2;
3. Coordinating with Finance on the retention and accessibility of Financial Records;
4. Coordinating with Legal on legal holds, anonymization questions, and destruction of legally sensitive records;
5. Ensuring that PMG-approved storage platforms are used for all records within scope;
6. Responding to audit or regulatory requests for records in coordination with Legal.

8.2 Individual PMG personnel are responsible for:

1. Storing all records created or received in connection with their engagements on PMG-approved platforms from the point of creation or receipt;
2. Notifying the Projects Team immediately when an engagement concludes so that the retention clock can be started;
3. Digitizing any physical records received and arranging their physical destruction in accordance with Section 7;
4. Notifying the Projects Team immediately if they become aware of actual or anticipated litigation, regulatory investigation, or other circumstances that may require a legal hold.

8.3 PMG Legal is responsible for:

1. Issuing and lifting legal holds in respect of records subject to or potentially subject to legal proceedings or regulatory investigation;
2. Advising the Projects Team on anonymization adequacy where uncertainty exists;
3. Advising on jurisdiction-specific retention obligations where local law may require retention periods beyond the global minimums in this policy.

8.4 Regional business units and licensees are responsible for establishing and maintaining supplementary retention schedules where required by local law, and for ensuring those schedules are communicated to the Projects Team. Where a regional schedule imposes a longer retention period than this policy, the regional standard governs for records within that jurisdiction.

9. Relationship to Other PMG Policies

9.1 This policy should be read alongside the following PMG policies, each of which creates specific records that are subject to the retention standards set out here:

1. The Intellectual Property Policy, under which all PMG Work Product created using PMG resources is owned by PMG and retained indefinitely as a core IP asset;
2. The Whistleblower & Speak-Up Policy, under which investigation records are retained indefinitely given PMG's absolute confidentiality obligations and the potential for related legal exposure;
3. The Anti-Bribery & Corruption Policy, under which books, records, and the gifts and hospitality register must be maintained accurately and are subject to the Financial Records retention period;
4. The Expense & Procurement Policy, under which expense submissions, vendor quotes, selection justifications, and Connected Vendor disclosures must be retained and are subject to the Financial Records retention period where they constitute financial transactions;
5. The Conflict of Interest & Client Segregation Policy, under which all disclosures, assessments, and mandated actions documented by the Ethics Officer are internal records subject to retention standards set at the team level;
6. The Political & Government Advisory Services Policy, under which lobbying registrations and expenditure disclosures are subject to statutory retention obligations in multiple jurisdictions, which may exceed the global minimums in this policy.

10. Policy Governance

10.1 This policy is administered by the Projects Team in consultation with PMG Legal. Questions regarding the interpretation or application of this policy should be directed to projects@askpmg.com.
10.2 PMG reserves the right to amend this policy at any time. Material amendments will be communicated to all PMG personnel and to regional business units and licensees where the amendment materially affects their obligations.