Ethics and Acceptance Master Class

Understanding the core principles and processes for audit engagement.

1. The Need for Professional Ethics

Professional accountants have a responsibility to act in the public interest. The purpose of assurance engagements is to increase the confidence of the intended users, so they need to trust the provider. This requires the assurance provider to be independent of their client, meaning they are free from situations and relationships that would impair objectivity.

2. The Conceptual Framework

The ACCA and IESBA codes of ethics follow a conceptual framework that identifies the fundamental principles, potential threats to those principles, and possible safeguards to eliminate or reduce the threats to an acceptable level. This framework uses a principles-based approach, which requires professional judgment and is flexible enough to apply to new and unusual situations.

The relationship can be broken down as follows:

  • The IESBA Code of Ethics and the ACCA Code of Ethics and Conduct both form the basis for the Conceptual Framework.
  • This framework is built on three core pillars:
    • Fundamental Principles: The ethical standards expected of a professional accountant.
    • Threats: Situations that may compromise the fundamental principles.
    • Safeguards: Actions to eliminate or reduce threats to an acceptable level.

The Fundamental Principles

Integrity: Be straightforward and honest.

Objectivity: Don't let bias, conflicts, or undue influence compromise professional judgment.

Confidentiality: Respect the confidentiality of information and don't disclose it without proper authority.

Professional Competence and Due Care: Maintain the necessary professional knowledge and skill to provide competent services.

Professional Behaviour: Comply with laws and regulations and avoid any conduct that might discredit the profession.

3. Threats to Objectivity and Safeguards

Auditors must identify, assess, and address any threats that could compromise their objectivity. A safeguard is an action that eliminates a threat or reduces it to an acceptable level.

There are five main threats to objectivity, often interconnected:

  • Self-Interest: The auditor has a financial or other interest that inappropriately influences their judgment.
  • Self-Review: The auditor performs non-audit work for a client that is then subject to audit.
  • Familiarity: The auditor becomes too sympathetic or trusting of a client, losing professional skepticism.
  • Intimidation: The client attempts to exercise undue influence over the auditor.
  • Advocacy: The auditor promotes the client's position, taking their side in a dispute or a public forum.

Threats & Safeguards in Detail

Self-Interest Threats

The auditor has a financial or other interest that inappropriately influences their judgment.

Threat Safeguards
Fee dependency Increase the client base, or have an independent review of the work. For listed clients, this is presumed when fees exceed 15% for two consecutive years.
Financial interests (e.g., owning shares) Dispose of the financial interest immediately. Neither the firm nor any audit team member can hold a direct or material indirect financial interest in the client.
Gifts and hospitality Do not accept gifts or hospitality unless the value is trivial and inconsequential.

Self-Review Threats

The auditor performs non-audit work for a client that will then be subject to audit, making them unlikely to admit or detect their own errors.

Threat Safeguards
Accounting and bookkeeping services For non-listed clients, only provide routine or mechanical services. Use a separate team, and have a reviewer not involved in the service check the work. Prohibited for listed clients.
Tax and valuation services Use a separate team. The audit firm cannot represent the client in a dispute that is material to the financial statements. Prohibited for listed clients if material.

Familiarity Threats

The auditor becomes too sympathetic or trusting of a client, losing professional skepticism.

Threat Safeguards
Long association of senior personnel Rotate senior personnel off the audit team. For listed clients, there are mandatory rotation and cooling-off periods (e.g., 5 years for an engagement partner).
Family and personal relationships Remove the individual from the engagement team, especially if the family member can exert significant influence over the financial statements.

Advocacy Threats

The auditor promotes the client's position, taking their side in a dispute or a public forum.

Threat Safeguards
Representing the client in a dispute Decline the engagement. The firm cannot act as an advocate for the client before a public tribunal or court if the amounts are material to the financial statements.
Promoting the client’s shares This is prohibited. The firm cannot underwrite, deal in, or promote the audit client's shares.

Intimidation Threats

The client attempts to exercise undue influence over the auditor.

Threat Safeguards
Fee dependency Increase the client base or have an independent review.
Litigation If the litigation is significant, the firm should consider withdrawing from the engagement.

4. Confidentiality and Conflicts of Interest

Auditors have a duty to keep client information confidential. This is only broken if there is a legal or professional right or duty to disclose. Examples include legal proceedings, money laundering, or when disclosure is in the public interest.

Conflicts of Interest:

A conflict arises when a firm audits two companies that compete or trade with each other. This can create threats to objectivity and confidentiality. To manage this, the firm must:

  • Disclose the conflict to all parties and get their consent.
  • Use separate engagement teams.
  • Have physical separation of confidential information.

5. Accepting an Audit Engagement

Before accepting a new engagement, an audit firm performs a client screening process to assess the level of risk. This process considers several factors.

Key issues to consider before accepting an engagement include:

  • Professional Clearance: The prospective auditor must communicate with the outgoing auditor to understand why they are leaving and if there are any professional reasons not to accept the appointment.
  • Preconditions for an Audit: The auditor must ensure that management acknowledges its responsibility for preparing the financial statements, maintaining internal controls, and providing full access to information.
  • Independence & Objectivity: The firm must confirm that it can maintain independence and objectivity throughout the engagement by identifying and managing any potential threats.
  • Reputation of the Client: The firm should consider whether its own reputation could be damaged by association with the client.
  • Management Integrity: If management lacks integrity, there is a greater risk of fraud and intimidation.
  • Professional Competence: The audit firm must have the necessary skill and experience to perform the work competently.
  • Money Laundering: The firm must comply with money laundering regulations and perform client due diligence.
  • Fees: The fee should be commensurate with the level of risk, and the client's creditworthiness should be considered.
  • Resources: The firm must have adequate resources to perform the work properly and on time.
  • Risks: Any risks identified with the client, such as poor performance or unusual transactions, should be assessed to manage the overall engagement risk.

Preconditions for an Audit

Before accepting an engagement, the auditor must ensure that management acknowledges their responsibility for:

  • The preparation of the financial statements in accordance with the applicable financial reporting framework.
  • Internal controls to enable the preparation of financial statements free from material misstatement.
  • Providing the auditor with full access to all relevant information.

The Engagement Letter

The engagement letter is a formal contract between the audit firm and the client. Its purpose is to confirm the acceptance of the engagement and set out the terms and conditions, minimizing the risk of any misunderstanding. The letter is typically sent before the audit commences and should be reviewed annually.

Test Your Understanding Questions and Solutions

Test your understanding 1: Murray Co case study

You are an audit manager in Wimble & Co, a large audit firm which specialises in providing audit and accountancy services to manufacturing companies. Murray Co has asked your firm to accept appointment as external auditor. Murray Co manufactures sports equipment. Your firm also audits Barker Co, another manufacturer of sports equipment, and therefore your firm is confident it has the experience to carry out the audit.

You have been asked to take on the role of audit manager for Murray Co, should your firm accept the engagement. You own a small number of shares in Murray Co, as you used to be an employee of the company. Don Henman, who has been the engagement partner for Barker Co for twelve years, will take the role of engagement partner for Murray Co. The audit senior will be Tim Andrews, as his sister is the financial controller at Murray Co and therefore he knows the business well.

Your firm recently purchased some bibs, footballs and other equipment from Murray Co for the firm's annual football tournament. Murray Co has offered to provide this equipment free of charge to the firm if they accept the role as auditor.

Murray Co would also like your firm to provide taxation and accounting services. Specifically, the company would like you to prepare the financial statements and represent the company in a dispute with the taxation authorities.

The fees for last year's audit of Barker Co have not yet been paid, and you have been asked by Don Henman to look into the matter.

Required:

(a) Describe the steps Wimble & Co should take to manage the conflict of interest arising from performing the audit of Murray Co and Barker Co.

(b) Explain SIX ethical threats which may affect the independence of Wimble & Co in respect of the audit of Murray Co or Barker Co, and for each threat identify ways in which the threat might be reduced.

Solution:

Part (a): Conflict of interest

Wimble & Co must inform both clients of the conflict and obtain their consent to act. Separate engagement teams should be used for each audit, and physical barriers should be put in place to limit access to confidential files. An independent review partner should be assigned to ensure the safeguards are effective.

Part (b): Ethical threats and safeguards

Ethical Threat Possible Safeguard
Financial interest: The audit manager owns shares in Murray Co, creating a self-interest threat. The audit manager must dispose of the shares immediately.
Previous employment: The audit manager used to work for Murray Co, creating a self-review and familiarity threat. The audit manager should not be assigned to the audit, especially if they would be auditing their own prior work.
Gifts and hospitality: The offer of free equipment creates a self-interest and familiarity threat. The firm should decline the offer, as it is not trivial or inconsequential.
Long association: The engagement partner has been with Barker Co for 12 years, creating a familiarity and self-interest threat. Rotate the senior personnel and perform an independent quality control review of the engagement.
Personal relationship: The audit senior's sister is the financial controller, creating a familiarity, self-interest, and intimidation threat. Tim Andrews must be removed from the audit team.
Advocacy: The request to represent the company in a tax dispute would be promoting the client's position. The firm must politely decline this service.
Overdue fees: Unpaid fees from Barker Co create a self-interest threat. Request payment immediately and do not perform further work until fees are paid.
Provision of other services: Preparing financial statements and providing tax services creates a self-review threat. Use separate, non-audit staff for these services and arrange for an independent review of the work.
Test your understanding 2

Question: Explain each of the FIVE fundamental principles of ACCA's Code of Ethics and Conduct.

Solution:

  • Integrity: A professional accountant must be straightforward and honest in all professional and business relationships.
  • Objectivity: An accountant must not allow bias, conflicts of interest, or undue influence to compromise their professional judgment.
  • Professional Competence and Due Care: An accountant must maintain professional knowledge and skill to ensure a client receives competent service, acting diligently and in accordance with applicable standards.
  • Confidentiality: An accountant must respect the confidentiality of information acquired and not disclose it without proper authority.
  • Professional Behaviour: An accountant must comply with relevant laws and regulations and avoid any conduct that might discredit the profession.
Test your understanding 3

You are a manager in the audit department of Whilling and Abel. A potential new client, Truckers Co, a haulage company, has approached your firm to perform the external audit in addition to some other non-audit services for the year-ending 30 September 20X5. Your audit firm was recommended to Truckers Co by an existing client, O&P, a shipping company who is also a major customer of Truckers Co.

You have been chosen to lead the engagement as you have experience of auditing haulage companies as you also manage the audit of O&P.

Whilst arranging the initial meeting with the directors of Truckers Co you discover that you studied accountancy with the finance director at university.

Truckers Co has not made a profit for the last two years. The directors explain that this is largely due to escalating costs in the industry including fuel price rises. They are confident they have now controlled their costs for the current year. They have also been approached to tender for a large profitable contract which would improve the company's financial performance going forward. They would like you to assist them with the preparation of this tender and present with them on the day.

The prior year financial statements are being audited by another audit firm. The finance director tells you that the current auditors have identified material misstatements but the board of directors are refusing to make these adjustments. If adjusted, it would turn the break-even position into a loss.

The current auditors have replied to your professional clearance letter and have informed you that they are still owed fees relating to the prior year.

You calculate that the potential fees from Truckers Co would amount to approximately 14% of your firm's total fee income.

Required:

(a) State the circumstances in which a person is not eligible to act as an auditor.

(b) Describe the steps required to remove an auditor from an engagement.

(c) Identify and explain THREE threats to objectivity if Whilling and Abel accept Truckers Co as a new audit client. For each threat, recommend how the threat can be managed.

(d) Explain the matters, other than ethical threats, that should be considered by Whilling and Abel prior to accepting the engagement.

Solution:

Part (a): Ineligibility to act as an auditor

A person is not eligible to act as an auditor if they are not a member of a Recognised Supervisory Body (RSB), or are an officer, employee, business partner, or a close family member of an officer or employee of the company.

Part (b): Removal of an auditor

To remove an auditor, a decision must be made by the shareholders at a general meeting. Advance notice must be given to the company and the auditors, and the auditors have the right to attend and speak at the meeting or have representations read on their behalf.

Part (c): Threats and safeguards

Ethical Threat Possible Safeguard
Familiarity Threat: The audit manager knows the finance director, creating a familiarity threat where they might be too trusting and not apply sufficient professional skepticism. A different audit manager should be assigned to the audit of Truckers Co.
Advocacy Threat: The audit firm has been asked to prepare a tender and present with the client, which is an act of promoting the client. The auditor should politely decline this invitation, as it would compromise objectivity.
Self-Interest Threat: The potential fee represents 14% of the firm's total income, creating a fee dependency. The firm should increase its client base to reduce dependency and have an independent review of the audit work.
Intimidation Threat: The directors are refusing to make adjustments, which indicates a threat to impartiality. The firm should carefully consider whether they can stand up to management pressure and maintain objectivity. If not, they should decline the engagement.

Part (d): Other considerations

In addition to ethical threats, Whilling and Abel should consider:

  • Professional clearance: The current auditors are owed fees, which is a significant issue.
  • Management integrity: The refusal to make adjustments to prevent a loss raises a serious question about management's integrity.
  • Preconditions for an audit: The firm must ensure management acknowledges their responsibilities.
  • Resources: The firm must have adequate resources to complete the audit on time.
  • Client's financial status: The company's loss-making history and potential financial difficulties increase the risk of the engagement.

Test your understanding 4

Question 1: Which of these is NOT a fundamental ethical principle?

  • A. Integrity
  • B. Independence
  • C. Objectivity
  • D. Professional competence and due care

Solution:
B. While independence is a crucial characteristic, it is not one of the five fundamental principles defined by the ACCA Code of Ethics.


Question 2: Which of these statements provides the best explanation of integrity?

  • A. Members should act diligently and in accordance with applicable technical and professional standards
  • B. Members should not bring the profession into disrepute
  • C. Members should not use client information for personal advantage
  • D. Members should be straightforward and honest in all professional and business relationships

Solution:
D. Integrity is defined as being straightforward and honest.


Question 3: A member was found guilty of ethical misconduct by failing to respond to the professional clearance requests from another audit firm. This is a breach of which fundamental principle?

  • A. Integrity
  • B. Independence
  • C. Professional behaviour
  • D. Professional competence and due care

Solution:
C. Professional behaviour includes professional courtesy, such as responding promptly to requests from other auditors.


Question 4: Which of the following statements best describes the conceptual framework approach to ethics?

  • A. A set of rules which must be followed in all circumstances
  • B. A set of principles which the auditor applies based on professional judgment
  • C. The conceptual framework is set out in company law
  • D. A set of principles which the auditor applies at their discretion

Solution:
B. The conceptual framework is a principles-based approach that requires the auditor to use professional judgment to apply the principles in various situations.


Question 5: Why do auditors need to be independent?

  • A. To ensure users of the auditor's report can place reliance on it and have faith it is not biased
  • B. To ensure the financial statements give a true and fair view
  • C. To provide more regulation for auditors to increase the perception of quality
  • D. The law requires it

Solution:
A. Independence ensures freedom from bias and influence, which is essential for users to trust the audit opinion.

Test your understanding 5

You are the audit manager responsible for the audit of Broome Co, a listed company. You have been informed by one of the audit juniors that the finance director has offered to take the audit team to a World Cup Final at the expense of the client as a thank you for an efficient audit.

The finance director has requested that you attend a social event where the company will outline a new rights issue of ordinary shares to shareholders. The finance director believes that the presence of the external auditor will add credibility to the rights issue and increase the chance of raising the required finance.

Question 1: Which of the following is NOT a threat to objectivity?

  • A. Independence
  • B. Self-review
  • C. Advocacy
  • D. Intimidation

Solution:
A. The threats to objectivity are self-interest, self-review, familiarity, advocacy, and intimidation. Independence is the state of being free from these threats, not a threat itself.


Question 2: Which ethical threat would be created if the audit manager attends the social event where the client will outline a new rights issue to shareholders?

  • A. Familiarity
  • B. Advocacy
  • C. Self-review
  • D. Self-interest

Solution:
B. Attending the event and appearing to support the rights issue would be an act of promoting the client, which is an advocacy threat.


Question 3: Which of the following is likely to be the most significant threat created by the offer of tickets to the World Cup Final?

  • A. Intimidation
  • B. Advocacy
  • C. Self-review
  • D. Self-interest

Solution:
D. The offer is a valuable gift, which creates a self-interest threat as the auditor may feel they owe the client a favorable audit opinion in return.


Question 4: What is the restriction, if any, on the level of fee income that can be received from recurring work from Broome Co before a situation of dependency is presumed to exist?

  • A. 5%
  • B. 10%
  • C. 15%
  • D. No restriction

Solution:
C. For a listed company, fee dependency is presumed when fees exceed 15% for two consecutive years.


Question 5: For clients where the level of fees must be monitored, what safeguard can the firm apply to reduce the threat to an acceptable level?

  • (i) Rotation of audit team members on an annual basis.
  • (ii) Discussion of the matter with the audit committee.
  • (iii) Assign an engagement quality control review partner.
  • A. (i) and (ii) only
  • B. (i) and (iii) only
  • C. (ii) and (iii) only
  • D. (i), (ii) and (iii)

Solution:
C. Discussing the matter with the audit committee and assigning an engagement quality control review partner are both valid safeguards for fee dependency. Rotation of the audit team does not directly address the fee dependency threat.