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Consultation: Restructuring and revising CIMA’s Code of Ethics

CIMA is proposing to publish an updated Code of Ethics (the CIMA Code) in 2019, to take effect from 1st January 2020. As a member of the International Federation of Accountants (IFAC), CIMA is committed to ensuring global professional standards are maintained at the highest level via adoption of the provisions of the International Ethics Standards Board for Accountants (IESBA) as and when substantive changes and significant improvements are made.

The CIMA Code was last updated in 2015. In 2018, the IESBA issued a revised and restructured code of ethics (the IESBA Code) which made several changes to both structure and content. CIMA was actively involved as a consultee in the restructuring work carried out by IESBA, and we consider the restructured IESBA Code offers a considerable improvement in terms of ease of use and navigation. Following the release of the new IESBA Code in April 2018, CIMA initiated a project to update the CIMA Code in line with the updated international standards. The revised CIMA Code will therefore reflect the new structure and format, comprising requirements and supporting application material, and content adopted in the new IESBA Code.

We consider it would be helpful for the updated CIMA Code to become effective at the beginning of the next calendar year, i.e. 1st January 2020. However, it is hoped that the new Code will be available to CIMA members and students in the summer of 2019 to align with the effective date of the new IESBA Code.

With these timescales in mind, CIMA is now inviting views on the draft version of its new Code, in particular:

  1. Are you in agreement with the new provisions and the new format adopted in the new Code?
  2. Are there any other provisions you consider should be included in the new Code which are currently unaccounted for?

Comments are welcome via email to ethicsconsultation2019@aicpa-cima.com.

CIMA reserves the right to modify the draft version of the new Code in the light of feedback received from this consultation, before a final version is signed off.

The consultation will close at 5pm on Friday, 31st May 2019.

Key changes

An enhanced conceptual framework:

The fundamental principles within the CIMA Code – integrity, objectivity, professional competence and due care, confidentiality, and professional behaviour – as well as the categories of threats to harm – self-review, self-interest, advocacy, familiarity and intimidation threats – will be unchanged. Also unchanged will be the overarching requirement to apply the conceptual framework to comply with the fundamental principles via adoption of the three-step process involving identifying, evaluating and addressing threats, and where applicable, independence. The conceptual framework however has undergone some revisions to strengthen it (section 120). These include new requirements to remain alert for new information that may result in the identification of a new threat, and to step back to review whether threats have been addressed as part of a member’s responsibility to properly address threats.

Safeguards:

The enhanced conceptual framework will also now include a more robust definition for safeguards which emphasizes that safeguards are applied to reduce threats to an acceptable level but cannot eliminate threats (R120.10). Conditions, policies, and procedures will no longer be considered as safeguards. Examples of safeguards will be more tightly integrated within the CIMA Code as is the case with the new IESBA Code.

Professional judgment and professional scepticism:

New material will be added to help professional accountants better understand what to consider in exercising professional judgment (R120.5). New application material will also explain how compliance with the fundamental principles supports the exercise of professional skepticism in audits, reviews, and other assurance engagements (R120.13 A1 – A2).

Pressure to breach the fundamental principles:

There will be a new section (section 280) requiring CIMA members to not allow pressure to result in a breach of the fundamental principles and not place pressure on others that would result in a breach of the fundamental principles.

Inducements (including gifts and hospitality):

The new CIMA Code will contain extensive revisions to align provisions relating to inducements for members in business and members in practice to provide a large degree of symmetry between the two. This will mirror enhancements made in the revised IESBA Code. The new provisions will provide more detailed guidance on how members should address inducements. A new requirement will explicitly prohibit members in business or practice offering or accepting an inducement prohibited by laws and regulations such as those related to bribery and corruption. Guidance on inducements that are not prohibited by laws and regulations will then be divided into two types: inducements with intent to improperly influence behaviour (improper intent) and inducements with no intent to improperly influence behaviour.