1. CPA Code
ifac is regulated by the Institute of Certified Public Accountants in Ireland (CPA Ireland) and is governed by CPA Ireland’s Code of Ethics for all Members (the “CPA Code”).
CPA Ireland adopted the International Code of Ethics for Professional Accountants (including International Independence Standards) issued by the International Ethics Standards Board for Accountants (IESBA).
The CPA Code sets out high quality standards of ethical behaviour expected of members for adoption by CPA Ireland, which is a member body of the International Federation of Accountants (IFAC) or for use by such members as a basis for their codes of ethics. The CPA Code forms the basis for ifac’s Code of Ethics set out herein (“ifac’s Code”).
At ifac we are committed to acting in the public interest and to ensuring that ethical principles are observed, and the highest professional and ethical standards are maintained. The CPA Code reaffirms our responsibility to act in the public interest and the fundamental role of the CPA Code in discharging that responsibility. This is achieved by compliance with the requirements of the CPA Code. As required by the CPA Code, in acting in the public interest we will consider not only the preferences or requirements of our clients, but also the interests of other stakeholders when providing our professional services.
All personnel of ifac have a responsibility to read, understand and comply with the CPA Code, subject as set out in paragraph 5 below.
2. Definitions
Unless otherwise specified herein and where the context admits or requires, references to:
“ifac” means Irish Farm Accounts Co-operative Society Limited, trading as ifac, and all its subsidiaries;
“member” includes any individual, person, partner, partnership, body or entity regulated or governed by CPA Ireland and/or a member of CPA Ireland and “members” shall have a corresponding meaning;
“personnel” includes the employees, partners, executive directors, principals, directors and other officers of ifac;
“we”, “our”, “ourselves” or “us” are references to ifac and/or its subsidiaries and the personnel of ifacand/or its subsidiaries.
3. Role of ifac’s Code
We are committed to:
integrity and the quality of our professional services, which underpins our day-to-day conduct of business at ifac;
conducting our business and serving our clients following the highest standards of ethical conduct and behaviour; and
delivering quality services that reflect our professional abilities and strengths and are appropriate and relevant to the requirements and needs of our clients.
ifac’s Code provides a set of ethical standards for our business conduct that we must all uphold and is intended to support us in our day-to-day operations at ifac. ifac’s Code also provides each of us with ethical and behavioural guidance to address challenging and difficult situations that we may encounter.
ifac’s Code reinforces:
our commitment to ethics and integrity, which are fundamental to our business conduct and day to day operations; and
the importance of conducting business and providing our professional services in accordance with professional standards, laws and regulations.
ifac’s Code applies to all personnel, irrespective of their individual role or position or membership of a regulatory or governing body. Accordingly, each of us is expected to become acquainted with, understand and comply with ifac’s Code. By complying with ifac’s Code, we demonstrate our strong commitment to ethical behaviour, integrity and quality, protect the reputation of ifac and help maintain a positive working environment. There can be serious consequences for non-compliance with ifac’s Code, which may result in disciplinary action up to and including dismissal.
4. The Five Fundamental Principles of Ethics
The CPA Code established five fundamental principles of ethics (the “fundamental principles”) to be complied with by all members, which we shall comply with and use to guide our behaviour and conduct in our day-to-day activities at ifac. These fundamental principles are as follows:
4.1 Integrity
We shall:
(i) be straightforward, fair and honest in all professional and business relationships;
(ii) be truthful about the services that we provide, the knowledge that we possess and the experience that we have gained;
(iii) act appropriately, even when facing pressure to do otherwise or when doing so might create potential adverse personal or organisational consequences.
Acting appropriately involves:
standing one’s ground when confronted by dilemmas and difficult situations; or
challenging others as and when circumstances warrant, in a manner appropriate to the circumstances.
4.2 Objectivity
We shall:
(i) be objective in forming our professional opinions and the professional advice that we give to our clients;
(ii) not allow bias, conflict of interest or undue influence of or undue reliance on individuals, organisations, technology or other factors to compromise our professional or business judgments and responsibilities;
(iii) not undertake a professional activity, including provide a professional
service, if a circumstance or relationship unduly influences our judgment regarding that activity;
(iv) take reasonable steps to identify circumstances that might create a conflict of interest, to include identifying:
the nature of the relevant interests and relationships between the parties involved; and
the activity and its implication for relevant parties.
(v) remain alert to changes over time in the nature of the activities, interests and relationships that might create a conflict of interest while performing a professional activity.
4.3 Professional Competence and Due Care
We shall:
(i) attain and maintain professional knowledge and skill at the level required to ensure that our clients receive a competent professional service based on current technical developments in practice, relevant legislation and techniques;
(ii) act diligently and in accordance with applicable technical and professional standards when providing professional services;
(iii) maintain professional competence, which requires a continuing awareness and understanding of relevant technical, professional and business developments;
(iv) ensure that our continual professional development requirements are met;
(v) take reasonable steps to ensure that all personnel working under our authority in a professional capacity have appropriate training and supervision, where required;
(vi) where appropriate, make our clients aware of limitations inherent in our professional services or activities.
4.4 Confidentiality
We shall:
(i) respect the confidentiality of information acquired as a result of professional and business relationships and not disclose any such information to third parties without proper and specific authority unless there is a legal or professional right or duty to disclose;
(ii) be alert to the possibility of inadvertent disclosure, including in a social environment, and particularly to a close business associate or an immediate or a close family member;
(iii) maintain confidentiality of information within ifac;
(iv) maintain confidentiality of information disclosed by a prospective client;
(v) not use confidential information acquired as a result of professional and business relationships for our personal advantage or for the advantage of a third party;
(vi) not use or disclose any confidential information, either acquired or received as a result of a professional or business relationship, after that relationship has ended; and
(vii) take reasonable steps to ensure that personnel under our control, and individuals from whom advice and assistance are obtained, respect our duty of confidentiality.
We protect and safeguard confidential information that we hold and adhere to stringent data privacy, data protection and security standards, applicable laws, professional obligations and our own data management policy and procedures.
Confidentiality serves the public interest because it facilitates the free flow of information from our client to us in the knowledge that the information will not be disclosed to a third party. Nevertheless, the following are circumstances where we are or might be required to disclose confidential information or when such disclosure might be appropriate:
a) Disclosure is required by law, for example, production of documents or provision of evidence in the course of legal proceedings or disclosure to the appropriate public authorities of infringements of the law that come to light;
b) Disclosure is permitted by law and is authorised by the client;
c) There is a professional duty or right to disclose, when not prohibited by law to:
comply with the quality review of CPA Ireland;
respond to an inquiry or investigation by CPA Ireland or other regulatory body;
protect our professional interests in legal proceedings; or
comply with technical and professional standards, including ethics’ requirements.
In deciding whether to disclose confidential information, we shall consider the following factors, depending on the circumstances:
whether the interests of any parties, including third parties whose interests might be affected, could be harmed if the client consents to the disclosure of information by us;
whether all the relevant information is known and substantiated, to the extent practicable.
We shall continue to comply with the principle of confidentiality after the end of the relationship between us and a client. When changing employment or acquiring a new client, we are entitled to use prior experience but shall not use or disclose any confidential information acquired or received as a result of a professional or business relationship.
4.5 Professional Behaviour
We shall:
(i) comply with all relevant laws and regulations;
(ii) behave in a manner consistent with the accountancy profession’s responsibility to act in the public interest in all professional activities and business relationships;
(iii) avoid any conduct that we know or should know might discredit ourselves and/or the accountancy profession;
(iv) not knowingly engage in any business, occupation or activity that impairs or might impair the integrity, objectivity or good reputation of the accountancy profession and as a result would be incompatible with the fundamental principles;
(v) when undertaking marketing or promotional activities, not bring the accountancy profession into disrepute;
(vi) be honest and truthful and not make:
exaggerated claims for the services offered by us or our qualifications or experience; or
disparaging references or unsubstantiated comparisons to the work of others.
5. Compliance with the CPA Code
These fundamental principles establish the standard of behaviour expected of all members of CPA Ireland, which all personnel should observe. These fundamental principles are an appropriate frame of reference in considering what constitutes unethical behaviour on our part and, if necessary, by analogy, other individuals.
At ifac we are committed to ensuring compliance with the CPA Code, including these fundamental principles. Upholding these fundamental principles and compliance with the specific requirements of the CPA Code enables us to meet our responsibility to act in the public interest. However, the CPA Code recognises that compliance with its requirements does not mean that we will have always met our responsibility to act in the public interest, in that we might encounter:
unusual circumstances in which we believe that the result of applying a specific requirement of the CPA Code would be disproportionate or might not be in the public interest; or
a situation in which complying with one of the fundamental principles of the CPA Code conflicts with one or more of these fundamental principles.
If any such issue arises, personnel are encouraged to discuss same within ifac with:
another colleague(s), if appropriate;
their Line Manager;
Legal Counsel; and/or
the Chief Executive Officer of ifac (the “CEO”).
If the issue is not resolved after any such discussion, we may consult with CPA Ireland regarding same.
The principle of confidentiality applies to any such discussion, including the disclosure and sharing of information with the parties concerned.
However, any such discussion does not relieve us from the responsibility to exercise professional judgment to resolve the issue. We will document the substance of the issue, the details of and rationale for any such discussion and the decision made.
There can be serious consequences for non-compliance with the CPA Code, which may result in disciplinary action up to and including dismissal. In addition, if a member fails to comply with the CPA Code, it may lead to disciplinary action as outlined in CPA Ireland’s Bye-Law 6 – Discipline.
However, the CPA Code provides that if there are circumstances where laws or regulations preclude compliance with certain parts of the CPA Code, those laws and regulations prevail, and all other parts of the CPA Code shall be complied with.
6. Inducements, including Gifts, Hospitality and Entertainment
We are required to comply with the fundamental principles and identify, evaluate and address threats to compliance with same. Offering or accepting inducements might create a self-interest, familiarity or intimidation threat to compliance with these fundamental principles, particularly the principles of integrity, objectivity and professional behaviour.
An inducement is an object, situation or action that is used as a means to influence an individual’s behaviour, but not necessarily with the intent to improperly influence their behaviour. An inducement is considered as improperly influencing an individual’s behaviour if it causes them to act in an unethical manner. Such improper influence can be directed either towards the recipient or another individual who has some relationship with the recipient. Inducements can range from minor acts of hospitality between business colleagues to acts that result in non-compliance with laws and regulations. An inducement can take many different forms, for example:
Gifts;
Hospitality;
Entertainment;
Political contributions;
Charitable donations;
Sponsorship;
Kickbacks in relation to goods or services provided (see definition in paragraph 7 below);
Appeals to friendship and loyalty;
Employment or other commercial opportunities;
Preferential treatment, rights or privileges.
There are laws and regulations, such as those related to bribery and corruption (see paragraph 7 below), that prohibit the offering or accepting of inducements in certain circumstances, and we shall comply with them when we encounter such circumstances.
However, the offering or accepting of inducements that is not prohibited by laws and regulations might still threaten or compromise compliance with these fundamental principles and therefore we will not offer or accept any such inducements. Such an inducement could arise where a person in business accepts hospitality, the nature of which could be perceived to be inappropriate were it to be publicly disclosed.
We shall not:
offer, or encourage others to offer, any inducement that is made, or which we consider a reasonable and informed third party would be likely to conclude is made, with the intent to improperly influence the behaviour of the recipient or of another individual; and/or
accept, or encourage others to accept, any inducement that we conclude is made, or consider a reasonable and informed third party would be likely to conclude is made, with the intent to improperly influence the behaviour of the recipient or of another individual.
For example, we shall not offer, provide, solicit or accept any gifts, entertainment, hospitality, sponsorship, political contributions or charitable donations or other inducement that we have reason to believe may be intended to improperly influence business decisions or behaviour or impair objectivity or if they could be reasonably considered to:
improperly influence ifac’s business relationship with, or create an obligation to a client, supplier, contractor or other stakeholder;
breach laws, professional standards and regulations and/or the CPA Code;
constitute an unfair business inducement;
create a negative impact for ifac, including its reputation.
No personnel nor any member of their immediate family should use their position within ifac to solicit any money, gifts, entertainment, hospitability, sponsorship or free services from any client, supplier, contractor or other stakeholder for their benefit or any other person’s benefit.
7. Anti-Corruption and Bribery
We are totally opposed to corruption and bribery in any form and adopt a zero-tolerance approach to same. The making of bribes in any form or acceptance of them or inducing or permitting any other party to make or receive such bribes on behalf of any person shall not be tolerated under any circumstances. Bribes include political contributions, charitable donations, kickbacks, gifts, entertainment and hospitality, which may be construed as subterfuge for bribery. In addition, soft dollar practices are prohibited. A “kickback” arises where a person, e.g. an employee or contractor, receives money, goods or services in return for providing favourable treatment or a business opportunity to another person. A “soft dollar practice” includes the use of customer commissions by an investment adviser or money manager to pay for research and other services that benefit the investment adviser or money manager.
We do not contribute funds or resources towards any political party, political candidate, political campaign or politically affiliated organisation. We ensure that before we provide sponsorship or a charitable donation, we undertake the necessary due diligence, including from a risk perspective. We monitor the appropriate and proper use of our funds and resources.
We comply with all applicable laws, including laws governing anti-bribery and anti-corruption. We support all efforts to eradicate corruption, bribery and financial crime. Personnel should refer to our Anti-Bribery and Corruption Policy for further information.
We verify the identity or our clients and understand the nature of their business activities and adhere to the relevant anti-money laundering legislation and standards. We will not knowingly accept funds that are derived from unlawful sources or activities. We take the required action when suspicious or criminal behaviour is observed and reported in accordance with our anti-money laundering policies and procedures; personnel should refer to our manual in that regard for further information.
8. Social responsibility, sustainability and community involvement
We recognise our responsibility to play an active and positive role in supporting a sustainable society and community. We are committed to undertaking our business activities in a manner that upholds ethical values and respects every individual, communities and the natural environment. We will continue to work towards the sustainable improvement of our business by providing quality services to the highest standard with the utmost integrity and maintaining a working environment that contributes to the professional development of our personnel. We have a Corporate Social Responsibility (“CSR”) Policy, which outlines our CSR strategy and can be viewed on our website.
We are committed to conducting our business operations in an environmentally responsible and sustainable manner and endeavouring to minimise our environmental footprint. We endeavour to minimise the impact of our business on the environment through our direct operations and relationships with responsible suppliers. We established a Green Team in [2021] comprising certain members of our personnel who promote environmentally responsible practices. We also have a green champion (i.e. staff member) in each of our 30 offices who assist in communicating and implementing these practices. In addition, we have an Environmental Charter, which asserts our vision to be a climate positive business using the best of who we are to create and achieve environmental sustainability in our community. That Charter can be viewed on our website.
All personnel should consider the environmental impact of their decisions on how and where they work, particularly in relation to travel, waste, energy use and supplier relationships and how they can reduce their carbon footprint. We have a range of supports in place for personnel to encourage sustainable practices, including a bike to work scheme, hybrid working and EV charging. Our Human Resources Team can be contacted for information regarding these practices and please refer to our Flexible Working Policy for information regarding our hybrid working arrangement.
We support our communities where our 30 offices are located in a variety of ways, such as donating money to charitable causes and supporting volunteerism by our personnel. Many of our personnel support the local communities in which they live and work by volunteering their time to worthwhile causes and ifac supports and encourages same.
9. Respect, diversity and fair treatment
We are committed to maintaining a culture and working environment where everyone treats each other with respect, courtesy and fairness, promoting equal opportunity for all. We encourage and value different opinions, skills, and experiences. We are committed to maintaining an inclusive working environment that not only addresses individual needs but allows everyone to use their unique strengths.
We do not tolerate in our working environment bullying, harassment, retaliation, intimidation, disrespectful behaviour or discrimination of any nature on the grounds of gender, race, ethnicity, religion, age, disability, gender identity, sexual orientation and any other categories protected by law.
Personnel should refer to our Gender Equality, Diversity & Inclusion Charter for further information.
10. Guidance for decision making/Consultation
At a minimum, the decisions that we make, and our actions must be in accordance with all relevant laws, professional standards and regulations. However, while a decision or an action may be within the law, this does not necessarily mean that it is ethical. Each of us should ask ourselves the following questions to assist in making the right decision about a possible decision or action:
How do I feel about my decision or action, e.g. am I personally comfortable with it?
Am I being fair and honest and acting with integrity?
Am I witnessing discriminating behaviour?
Is there a potential conflict of interest?
Would the reputation of ifac be adversely affected or harmed if my decision or action was revealed in the public domain?
Could someone be adversely affected or harmed by my decision or action?
Could my decision or action appear inappropriate to a third party?
Have I consulted with the appropriate persons, listened to their perspectives with an open mind and considered all options before acting?
You do not have to resolve a difficult ethical decision or action alone. We encourage you to consult with:
another colleague(s), if appropriate;
your Line Manager;
Legal Counsel; and/or
the CEO.
When seeking the guidance of others within ifac, the principle of confidentiality applies.
We have a responsibility to raise our voice when we become aware of anything that is inconsistent with ifac’sCode or compromises the principles of ifac’s Code. At ifac we remain firmly committed to a working environment in which we feel comfortable raising a concern and in which we respond quickly, objectively and effectively when others raise concerns. ifac is committed to conducting an appropriate, timely and objective investigation following the raising of any such concern, where required. We are responsible for co-operating during the investigation process and for responding to questions truthfully, accurately and completely in a prompt manner. Failure to co-operate may result in disciplinary action.
Retaliation against those who raise concerns in good faith is not tolerated. Anyone who takes such retaliation will be held accountable and subject to disciplinary action.
Personnel are referred to our Whistle Blowing Policy & Procedure, where applicable, for further information.
11. Breach of ifac’s Code
ifac will respond appropriately to any breach of ifac’s Code, including any ethics’ and compliance issues that may involve a breach of laws, professional standards, regulations and/or the CPA Code. Determining whether such a breach has occurred involves significant judgment and will be based on the individual facts and circumstances of the specific case and ifac’s Disciplinary Procedure will apply. The responsibility falls to all involved in an investigation of any such breach to co-operate fully and respond honestly, accurately and promptly to all enquiries made during the course of the investigation.
ifac may, based on the results of an investigation, impose corrective action and/or a disciplinary sanction up to and including dismissal, to address any such breach in accordance with its Disciplinary Procedure.
Where ifac deems appropriate, it will report any such breach to and/or co-operate with the relevant authorities, including CPA Ireland, in any investigation.
12. Other Governing Bodies’ Codes of Ethics/Professional Conduct
In addition to complying with ifac’s Code, personnel who are regulated by another governing/regulatory body are required to comply with that body’s professional standards and relevant Code of Ethics and/or Code of Professional Conduct.
In order to comply with relevant regulations and professional standards, many of our personnel are required to hold professional licences, practising certificates and other certifications. All personnel holding such licences, certificates and other certifications have a personal responsibility to maintain same in good standing by means of timely renewals and where required, the attainment of the appropriate level of continuing professional development and education.
13. Review of ifac’s Code
ifac’s Code provides guidance on the behavioural expectations of ifac and its personnel and is not intended to create nor does it constitute a contract or an enforceable agreement of any kind against ifac. ifac’s Code will be kept under review and is subject to change from time to time. ifac reserves the right to amend this Code at any stage in whole or in part for any reason and without prior notice, consent or approval. Any such amendments will be communicated to all personnel.