CIMA's advice

The Code of Ethics would help her to think through which principles were at issue and her obligations as a CIMA member. The code also contains practical guidance on the steps that accountants should take in resolving an ethical conflict (section 100.16 – 100.21). Part of this advice is to consider all of the relevant facts and information.

In this case CM knew that people were being paid cash in hand, but didn’t know for sure that they were working in the UK illegally.

When she called the helpline, CIMA advised her to raise the issue with the two owner/directors. If they did not take her concerns seriously, then we advised her to think of someone else who might be able to influence the situation. There were other company directors but they were not involved in running it, so CM felt it pointless to approach them. There were no external auditors of the company to call on for help.

CM had already decided that she would probably resign, as she did not want to work for a company that was run this way.

If, having spoken to the owners, CM had found them unwilling to rectify the problem, she would still have a responsibility to try and resolve the non-payment of tax, whether she remained at the company or not. We recommended that she contact the Whistleblowing Advice Line. It offers free, confidential advice on how to raise a concern about malpractice at work before making a disclosure. We also suggested that she look at the HMRC website to find out whether and how she could report the non-payment of tax to the authorities.

There was also a possibility that this was a money laundering offence, and so CM was advised to look at CIMA’s Anti-Money Laundering Guidelines to establish whether a report needed to be made to the Serious Organised Crime Agency (SOCA).