Stop harm sooner... by speaking-up safely

Blurred background whistleblowing
By Paul Boyle CA, OBE

10 April 2018

Professional accountants might well encounter inappropriate or unethical behaviour at some stage of their careers.

It is a hallmark of professional accountants that they need to have regard not only to their own interests, or those of their clients or employers but also to the public interest.

These obligations mean that we cannot just turn a blind eye if we become aware of, or concerned about, unethical behaviour. The codes of ethics of professional bodies such as ICAS give some guidance as to how accountants should respond.

How to respond to unethical behaviour

In some cases, the right course of action for the professional accountant will be relatively clear.

For example, if a staff member who reports to the professional accountant behaves unethically, then the behaviour needs to be challenged and, if appropriate, disciplinary action taken.

Auditors also have obligations, in certain cases, to report inappropriate behaviour by their clients to the relevant authorities. However, in other cases, the appropriate course of action will be less obvious.

When to become a whistleblower

In well-managed organisations with a good culture, professional accountants will feel confident that they can speak-up safely thereby helping to stop the harm sooner.

However, in other organisations, this will not be the case. Relevant procedures may not be well-publicised, or workers may feel uncomfortable about speaking up for fear of adverse consequences. In some cases, people may have spoken-up but remain concerned that the organisation has not responded adequately.

In such situations, professional accountants may need to consider whistleblowing (raising a concern outside of normal reporting lines, or outside the organisation). Whistleblowing can be a difficult and lonely experience. It can be helpful to talk about the situation to someone who can give an independent perspective. ICAS has an ethics helpline to which members (or students) can turn for advice.

However, members and students should also consider calling the Advice Line operated by Public Concern at Work (PCaW), the charity of which I am proud to be chairman. PCaW’s Advice Line is free, confidential and legally privileged. We receive thousands of calls each year which makes us well-placed to advise individuals.

Accountants in senior leadership roles

Accountants in senior leadership roles (i.e. Executives and Non-Executive Directors) have a degree of responsibility for everything that goes on in the organisation and an exposure to reputational risk when things go wrong.

And yet, the vast majority of organisations will be too large for executives and NEDs to have direct awareness of all of the activities in those organisations. For this reason, there has been increasing focus on the responsibility of executives and NEDs to establish an appropriate culture in their organisations.

However, it is not sufficient for executives and NEDs to set out the desired culture. They also need to take steps to ensure that it is operating in practice.

Internal auditors (sometimes referred to as “the eyes and ears of the Board”) can help executives and NEDs identify bad behaviour.

But even well-resourced internal audit teams might be only 1% of the workforce and they cannot be expected to see or hear every concern.

It would be much better if executives and NEDs could engage 100% of staff to be their eyes and ears through having appropriate and well-communicated speak-up arrangements.

But how can executives and NEDs establish how well their arrangements actually operate and how they compare to best practice?

PCaW is one source of independent experts to which they can turn. We provide specialist support on speaking-up to hundreds of clients, across the private and public sectors. Our expertise is informed by the experience of the tens of thousands of calls to our Advice Line. Let’s work together to stop harm sooner by speaking-up safely.

About Paul Boyle:
Paul is a member of ICAS and recently retired as Chief Audit Officer of Aviva plc. He was Chief Executive of the Financial Reporting Council 2004 – 2009 and President of the Chartered Institute of Internal Auditors 2016 - 2017. He is currently the Chair of legal whistleblowing charity, Public Concern at Work.


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