Approaches to developing and maintaining professional values, ethics and attitudes
Comments from ACCA
December 2006
General Comments
ACCA welcomes the publication of this IEPS as an instructive practice document. It gives comprehensive, but not overly prescriptive, guidance to member professional bodies on how to validate that their members have developed and maintain professional values, ethics and attitudes and that they act accordingly. The paper is a helpful summary and synthesis of the original paper, based on the research project on ethics education, undertaken by Philomena Leung et al.
The IEPS is useful in that it gives guidance on both the process and the content of professional ethics education. ACCA is satisfied that the ethics education framework (EEF) is a useful process model for member bodies to work with and welcomes inclusion of the eight subject areas mapped against IES 4 requirements. However ACCA would welcome some more explanation about where these areas originate from, why they were included and perhaps a little more justification of how some of these map across to the IES 4 topics identified.
However, ACCA is of the opinion that the IEPS affords sufficient guidance and flexibility to member bodies about how to deliver ethics education and training within their pre-qualification programmes and post-qualification and is therefore is still a useful supplement for IES 4.
The IAESB indicated that it was particularly interested in comments on the matters set out below:
ACCA will therefore comment on the following three questions.
- Section 2 of the proposed IEPS recommends two approaches to implementing the Ethics Education Framework, and suggests that member bodies may choose to follow one approach or mix elements of both. Are both recommended approaches equally helpful in implementing ethics education programs? Do you have any specific (positive or negative) comments on one or both approaches?
- The Stage-by-Stage approach recommends that a separate, assessed final course or module in ethics be introduced for students at Stage 3. Do you support such a recommendation? Please explain.
- Section 3 of the proposed IEPS emphasizes the importance of workplace learning in developing the professional values, ethics and attitudes of professional accountants both in pre-qualification and post-qualification education. Do you feel that highlighting the role of workplace learning in this document is useful? If so, are there other examples of good practice in workplace learning the IAESB could include in this IEPS?
Specific Comments
1) Section 2 of the proposed IEPS recommends two approaches to implementing the Ethics Education Framework, and suggests that member bodies may choose to follow one approach or mix elements of both. Are both recommended approaches equally helpful in implementing ethics education programs? Do you have any specific (positive or negative) comments on one or both approaches?
ACCA believes both methods have their merits as methodologies for assessing ethical competence. However, ACCA would suggest that the 'topic' approach is more limited in its application than the 'stage-by-stage' approach, which seems to be more consistent with the EEF. ACCA therefore believes that use of the 'topic' approach alone might be insufficient to support the development and maintenance of professional values, ethics and attitudes , although if a member body were to fully apply the 'stage-by-stage' approach, then the 'topic' approach would probably be unnecessary. However, the 'topic approach' is most useful as a benchmark for ensuring coverage of all the knowledge areas that IES 4 recommends as being necessary in paragraph 16.
ACCA recommends that the most effective way is to use these approaches as complementary methods as it is felt that this will help reinforce ethics and professionalism throughout the educational programme and post qualification at work.
ACCA envisages the 'topic' approach being used mainly to support stages 1 and 2 of the 'stage by stage' approach through giving students a basic knowledge and awareness of ethical issues, concepts and frameworks and making them aware and sensitive to the ethical problems and dimensions of decision making. ACCA would question whether the topic approach does extend to stages 3 and 4 as written, as these are probably best demonstrated and enhanced through work place learning and experience.
ACCA considers that the 'stage by stage approach' is the superior methodology in that it is broader based and explicitly emphasises the concept of 'life-long' learning and application in the workplace. It recognises that the student/trainee/professional embarks on a journey of ethical development, acquiring the knowledge, developing the sensitivity through exposure to dilemmas and conflicts, improving their ethical judgement and maturity, to finally inculcating a 'value set' to which they will remain committed and continue to act upon in their professional work. ACCA also sees the 'stage by stage' approach as a cycle through which students, trainees and members will keep moving, where appropriate new ethical knowledge, insights and experiences create a cumulative effect on the ethical maturity and competence of the professional to make better and more informed decisions and to have the confidence to act and behave responsibly in all situations.
Intuitively ACCA therefore prefers the 'stage-by-stage' approach because it implies that ethical development is more than just about learning ethical theories or even developing ethical sensitivity. It requires some exposure to 'ethical problems' such as threats, dilemmas and conflicts, initially through simulated assessments, interactive tests and exercises and also by examination during pre-qualification. However, it also recognises that the last two stages must, by implication, be fulfilled through pre-qualification work experience while training and post-qualification when faced with difficult decisions and choices at work.
The last stage recognises that continuing professional development (CPD) should be used as the vehicle for supporting 'life-long' learning and development and ACCA agrees that this approach is necessary to maintaining professional values, ethics and attitudes.
ACCA therefore recommends that the 'stage by stage' approach is probably more robust, comprehensive and has a better 'fitness for purpose' than the 'topic approach' used alone.
2) The Stage-by-Stage approach recommends that a separate, assessed final course or module in ethics be introduced for students at Stage 3. Do you support such a recommendation? Please explain.
ACCA strongly supports the IEPS recommendation for the inclusion of an assessed final level course or module in ethics for students. ACCA believes this is important for three main reasons:
- It gives ethics a prominent syllabus role alongside the specialist accounting related subjects a member body might include at the highest level. This sends out the strong message to students and other stakeholders involved with the teaching, learning, training and development process that ethics is an essential and high level subject and discipline.
- Placing an ethics paper at the highest level in a pre-qualification programme ensures sufficient underpinning coverage of technical accounting and finance, so that more relevant and sophisticated 'scenarios' can be used within which to assess the application of ethical knowledge, sensitivity and judgment within a realistic context.
- Having a final level examination in ethics (particularly at the beginning of that level) also allows students to take forward their ethical sensitivity and judgment into their study of advanced specialisms, in such subjects as financial reporting, business analysis, taxation, performance management, finance and audit. This allows examiners of these high level subjects to integrate and apply complex ethical situations, threats and conflicts into the specific context of their subject disciplines.
3) Section 3 of the proposed IEPS emphasizes the importance of workplace learning in developing the professional values, ethics and attitudes of professional accountants both in pre-qualification and post-qualification education. Do you feel that highlighting the role of workplace learning in this document is useful? If so, are there other examples of good practice in workplace learning the IAESB could include in this IEPS?
ACCA welcomes the emphasis in the IEPS on post-qualification maintenance of ethical values and behaviour and the recognition that this is as important as the focus on enhancement of ethical knowledge and the development of ethical sensitivity in the pre-qualification education curriculum.
ACCA strongly supports the emphasis on the application of ethics and professionalism in the work place and feels that this is where the IEPS can help develop and expand on the recommendations of IES 4.
ACCA recognises that by applying the EEF and the 'stage-by-stage' approach as supported earlier (see response to Question 1), it is essential that member bodies require the demonstration and validation of work based competences relating to ethics, in order to properly fulfil the requirements of stages three and four in particular.
ACCA would suggest that maintaining and improving ethical behaviour can be most effectively demonstrated through exposure to real work-based situations and being involved in, if not deciding upon, courses of action involving ethical judgment. These work based situations could of course include audit related work or situations where relevant, but ethical threats and conflicts relating to other core areas of an accountant's work should also be recognised and explored, such as in preparing financial reports, giving tax advice, managing finance and the whole area of performance management and control.
ACCA would also recommend that stage 4 - maintaining an ongoing commitment to ethical behaviour, can best be demonstrated at work, and because of its long-term nature, this is most appropriately validated through CPD, post-qualification.
Paragraphs 42 - 50 are helpful in recognising that different models can be used for the delivery and assessment of ethics education, combining elements of workplace learning and formal education.
ACCA agrees that professional accountants and students, training to become professional accountants, should be exposed to exercises in ethical awareness and ethical decision-making. It also recommends that pre and post-qualification programmes should contain practical examples involving ethical threats and issues to help reinforce theoretical knowledge and sensitivity.
Paragraph 46 on the ethical leadership role is interesting, but could be difficult to apply in practice. However, ACCA believes that wherever possible, experiences of senior professionals of dealing with real ethical threats, conflicts and other problems and how these are resolved, are valuable lessons from which ethical sensitivity and maturity in more junior managers and professionals can be developed.
These kinds of experiences could be shared through presentations or 'briefings' by senior staff or consultants, through ethics discussions and from role play situations - as indicated in paragraph 51, without compromising the principle of 'confidentiality'.
ACCA would like to see this aspect explored where, for example, within professional accounting organisations a case history of such situations and experiences could be collected and documented. In a broader context, ethics 'web logs' or 'pod casts' could be created where accounting professionals can air and share their experiences of ethical situations and problems with others.
ACCA believes that the IEPS is right to focus on the role of the mentor, coach and or the supervisor/manager and their supportive one-to-one relationship with the trainee or member. It is also right to emphasise the importance of their role in developing and maintaining professional and ethical values. ACCA recognises an important point is therefore made in paragraph 48 when it is 'recommended that member bodies encourage supervisors or mentors to provide feedback on trainees' ethical judgment and behaviour, in addition to feedback on their technical performance .
This paragraph rightly places a broader responsibility to monitor and evaluate ethical as well as the technical. ACCA would welcome more guidance on how the IEPS would recommend the explicit inclusion of ethics in workplace training and appraisal, and how it would advise member bodies to validate this on a regular basis.
ACCA suggests however, that this could be done mainly through reflection and commentary, by journalising such situations on an ongoing basis and recording how ethical issues were handled or resolved. ACCA would initially expect 'trainees'/members to discuss these as they happen, or at least review the outcomes of such situations and how they were resolved with their first line contact, through appraisal. They should also use these discussions to explore and improve their ethical sensitivity and judgment, leading towards better ethical behaviour and decision-making. The IEPS seems to support this approach in what it says in paragraph 56.
ACCA welcomes the recommendations in both paragraphs 50 and 56 for feedback on ethical judgment and behaviour to be included as part of the formal appraisal and review process within organisations, although it should be recognised that in practice this might be difficult to achieve without it potentially becoming a contrived and rather artificial exercise.
Conclusions
ACCA is generally satisfied that the IEPS is a robust and helpful guidance document which supports the recommendations contained within IES 4. ACCA believes the 'stage by stage' approach is the superior learning process and if used effectively can include all the relevant subject areas identified within the 'topic approach and is consistent with the EEF.
ACCA also sees the 'stage-by stage' approach being used as a continuous 'learning cycle', for students, trainees and members to cumulatively develop their ethical maturity and behaviour in all the main stream areas of accounting which include audit, tax, financial reporting, finance and performance management.
ACCA agrees with the recommendation for a final level discrete examination on ethics and sees this as both supporting the notion of ethics as a high level and prominent subject in its own right, but also as a subject assuming a high level of technical knowledge in accounting so that complex ethical situations can be explored and applied within a proper context.
Finally, ACCA does support the emphasis on stages 3 and 4 of the EEF within the IEPS on improving ethical judgment and demonstrating commitment to ethical behaviour and its maintenance within the workplace. ACCA is comfortable with suggestions in paragraphs 42-50 on how this may be achieved in practice, but suggests that member bodies might appreciate a little more guidance on how this could be explicitly demonstrated.