Ethics Flashcards
(31 cards)
State the responsibilities of the MLRO with regard to reporting.
1) Receives internal information/report where there is knowledge or suspicion of money laundering.
2) The MLRO is then responsible for deciding whether the information contained in an internal report needs to be relayed to the NCA in the form of an external report, a SAR
3) Where are specific offences applying to MLROs failing to make a report where one is needed
Ruth wants to join the new project team, but she does not have all of the qualifications required. She has decided to submit false information about her qualifications to ensure she gains a place on the new project team
Integrity is threatened if Ruth submits false information.
Ruth should not knowingly be associated with any information that she knows:
contains a materially false or misleading statement; or
omits or obscures information required to be included where such omission or obscurity would be misleading.
Professional behaviour will be breached if Ruth submits false information.
Ruth should not make exaggerated claims for the services she is able to offer, the qualifications she possesses, or the experience she has gained.
The threat here is a self-interest threat which affect’s Ruth’s objectivity because she wants a job/money on the team and the financial reward, but if she tells the truth she may not be given one.
Liz will retire at the end of June 2025. She intends to cancel her professional indemnity insurance as soon as she retires.
Explain what action Liz should take with respect to her professional indemnity insurance in order to comply with the ICAEW’s Professional Indemnity Insurance Regulations
As a qualified member of ICAEW in public practice and resident in the UK, Liz should maintain cover for at least two years after her retirement, preferably for at least six years.
The minimum recommended level of cover is:
£250,000;
2.5 times fee income if cover then exceeds £250,000; or
preferably higher if Liz’s recent fee income has exceeded £800,000 pa
Kira is an ICAEW Chartered Accountant employed by a large accountancy firm in London. Kira is being seconded to work for HMRC for a six-month period. After this, Kira will return to work for her employer.
Any potential conflict of interest, actual or perceived, should be carefully managed and Kira should be removed from any situation where there is a conflict between HMRC’s and her employer’s interests.
Whilst on secondment Kira needs to be aware that she must serve the interests of HMRC/duty to HMRC/act for HMRC/responsible to HMRC.
Whilst working for HMRC Kira should not be involved in any matters relating to her employer or any of its/her clients.
For a significant period after the end of the secondment, Kira should not be involved in the affairs of any taxpayer she was involved with whilst at HMRC.
Jane is an ICAEW Chartered Accountant employed in practice. Jane gave a new client legal advice about the taxation of his offshore income. The client admitted to Jane that he had not been declaring his offshore income to HMRC. Jane advised him to declare the income to HMRC and to pay the tax owed, together with any interest and penalties due. Jane did not check that the client had followed her legal advice. She did not consider making a report to her money laundering reporting officer.
Jane’s client has now been convicted of money laundering. Jane is concerned that she may face prosecution for failure to report.
Explain which defence Jane could use against a charge of failure to report a suspicion of money laundering.
The privilege reporting exemption applies if knowledge or suspicion of money laundering came to Jane in privileged circumstances.
As Jane learnt about the tax evasion whilst giving legal advice the knowledge came to her as legally privileged information which she cannot disclose via a money laundering report.
Flash LLP is a firm of ICAEW Chartered Accountants. Eddie Allen, a professional accountant, is employed by Flash LLP and is currently on sick leave. On a review of Eddie’s correspondence in his absence the following have been found:
An email from Iris West, a client, which includes the following:
When preparing my 2020/21 tax return you said that no tax was payable on the termination payment of £80,000 from my former employer so it was not included in the return. I am extremely stressed as I have just received a ‘discovery assessment’ from HMRC demanding substantial tax plus interest relating to the termination payment. I cannot afford this, and I hold your firm entirely responsible for paying it.
Explain the steps Flash LLP should take to resolve the issue Iris has raised.
Flash LLP should immediately contact Iris to inform her that the matter is being investigated.
The firm should ascertain the relevant facts relating to the termination payment and the advice given at that point in time, and check that HMRC’s demand is correct.
It is advisable to document the current issue in writing, including any discussions with the client.
The firm should check the engagement letter for permission to contact HMRC if needed, or if not ask the client for permission. The firm should contact HMRC to confirm/refute the discovery assessment.
The firm may wish to obtain professional advice from ICAEW or legal advisors.
It may be appropriate to contact the firm’s providers of PII to let them know that there may be a claim.
Flash LLP may be required to pay any penalties or interest
A letter from HMRC querying a P11D submitted by Flash LLP in July 2025.
Eddie prepares all P11Ds on behalf of the firm and HMRC’s query relates to Eddie’s own P11D. On review, you discover that Eddie has omitted details of his company car in this P11D and in previous forms, although other employees’ cars are correctly shown on their forms
Explain the ethical and legal issues for Eddie surrounding his P11D form, and the actions that the firm should now take.
By preparing his own P11D in this way, Eddie has allowed a self-interest threat to affect his objectivity, integrity and professional behaviour in submitting an incorrect form in order to pay less tax.
Eddie’s actions amount to tax evasion as he has deliberately withheld information from HMRC/provided HMRC with false information by understating his employment income/omitting his car benefit.
It would not be tax evasion if this was simply a mistake, but it is likely it was deliberate. Eddie could be the subject of a criminal prosecution which may lead to fines and/ or imprisonment. This could also constitute money laundering.
ICAEW may take action against him.
The firm
The firm should contact HMRC immediately to correct the P11D and pay any underpaid employer NICs.
The firm should follow its own internal disciplinary procedures in relation to Eddie’s wrongdoing.
Sherazi LLP, a firm of ICAEW Chartered Accountants, recently tendered for tax compliance and advisory work for Javadi Ltd, a marketing company.
Sherazi LLP has received notice that the tender was successful. The partners in the firm are pleased as they already have another marketing company, Higgins Ltd, as a client and the firm intends to become a specialist in this business sector.
Identify the fundamental principles that are threatened if Sherazi LLP accepts Javadi Ltd as a client and set out the safeguards that can be put in place to manage the threats to those fundamental principles.
The fundamental principles threatened by Sherazi LLP accepting Javadi Ltd as a client are objectivity and confidentiality.
Sherazi LLP should do the following:
Notify Higgins Ltd and Javadi Ltd of the potential conflict in acting for them both.
Obtain consent from each party to act for both.
If consent is not obtained, then Sherazi LLP should not accept Javadi Ltd as a client.
Assuming consent is obtained, use separate engagement teams for each client.
Apply procedures to prevent access to information (physical separation of teams, secure data filing).
Issue clear guidelines to the engagement teams/ provide training on issues of security and confidentiality.
Use confidentiality agreements for employees and partners.
Sherazi LLP, a firm of ICAEW Chartered Accountants, recently tendered for tax compliance and advisory work for Javadi Ltd, a marketing company.
Sherazi LLP has received notice that the tender was successful. The partners in the firm are pleased as they already have another marketing company, Higgins Ltd, as a client and the firm intends to become a specialist in this business sector.
Assuming the threats are sufficiently reduced, explain any other steps Sherazi LLP should take before accepting Javadi Ltd as a client.
Before accepting the client Sherazi LLP should do the following:
Carry out customer due diligence to establish areas of risk
Verify the identity of Javadi Ltd and its directors and keep evidence of identification
Obtain professional clearance from their previous advisors
Prepare an appropriate engagement letter explaining the scope of responsibilities
Janet and John have been married for many years and have two young children. Together they have asked your firm for tax advice about their joint wills.
Janet and John disagree about some of the decisions that need to be made. Janet thinks the whole estate should pass to the surviving spouse absolutely. John thinks the whole estate should be placed into trust for the surviving spouse for life and then pass to the children absolutely. John’s idea would ensure protection of the assets for the children.
Explain the nature of the conflict of interest for your firm, and how this could be managed.
Nature of conflict
This conflict presents a self-interest threat to objectivity.
Janet and John are two separate clients/two individuals/act for both and should be advised accordingly.
Managing the conflict
Unless the potential conflict is clearly insignificant, safeguards should be put in place to mitigate the conflict.
Assuming we continue to act for both clients we could use separate engagement teams and separate meetings to ensure that each spouse receives impartial advice/without bias/without favouring either party without undue influence from the other part affecting their decisions.
Normally we would consider acting for only one party, but that is probably not a viable option in the preparation of joint wills.
If the conflict cannot be managed to an acceptable level, we should cease to act for both parties
You are aware that your client, Idris, has received a repayment of £1,000 from HMRC in error. Your engagement letter does not include an authority to disclose such matters to HMRC.
Explain what action you should take in relation to the error.
The client should be:
asked to authorise disclosure of the error to HMRC and to repay the amount
warned of the possible legal consequences of non-disclosure, including interest and penalties and possibly criminal prosecution
advised that if consent is not given, we will need to cease to act.
We should maintain a written record of all advice given.
Strictly, all errors should be disclosed. However, if the error is below a de minimis limit (PCRT suggests £200), then it may be reasonable to not disclose it. The £1,000 in this case is not de minimis.
If our client will not repay the £1,000, we should cease to act and consider that this amount becomes criminal proceeds so falls within money laundering.
John is an ICAEW Chartered Accountant working as a senior tax adviser for a firm of accountants. John has created a new tax planning scheme which he intends to promote to non-UK domiciled individuals.
John’s scheme can be promoted to all non-UK domiciled clients without the need to tailor it to their individual needs. The scheme utilises a previously unexploited loophole in tax legislation by implementing a number of highly contrived and artificial steps.
In his research John has discovered that:
although HMRC’s interpretation of the relevant tax legislation is contrary to what the scheme proposes, HMRC’s interpretation has never been tested before the Courts and is not specifically supported by the legislation, and
while the relevant tax legislation does not specifically deal with this exact situation, it is clear that this scheme would be contrary to what Parliament intended when the legislation was enacted.
John disagrees with HMRC’s interpretation and therefore does not intend to explain to potential clients that the scheme might be challenged by HMRC.
Laura, John’s manager and the firm’s managing partner, has reviewed the scheme. She has concluded that its promotion by an ICAEW member could put that member in conflict with the Standards for Tax Planning included in Professional Conduct in Relation to Taxation (PCRT)
Identify and explain three Standards for Tax Planning from PCRT which best support Laura’s conclusion.
Tax planning arrangements
Members must not create, encourage or promote tax planning arrangements or structures that:
set out to achieve results that are contrary to the clear intention of Parliament in enacting relevant legislation and/or
are highly artificial/contrived and seek to exploit shortcomings within the relevant legislation.
Client Specific
Tax planning must be specific to the particular client’s facts and circumstances.
Clients must be alerted to the wider risks and the implications of any courses of action.
Lawful
Tax planning should be based on a realistic assessment of the facts and on a credible view of the law.
The requirement to advise clients on material uncertainty in the law (including where HMRC take a different view) applies even if the practical likelihood of HMRC intervention is considered low.
Members should consider taking further advice appropriate to the risks and circumstances of the particular case, for example where litigation is likely.
Gustavo and Mike are in the process of setting up in partnership as ICAEW Chartered Accountants offering tax compliance services. They will advertise for clients once they have completed all necessary steps to set up the firm.
State the money-laundering and other regulatory requirements for tax practices which Gustavo and Mike must fulfil before starting in business.
Money laundering
Register for anti-money laundering (AML) supervision with ICAEW as the appropriate supervisory body
Appoint a Money Laundering Reporting Officer (MLRO)
Train the partners and staff in relation to money laundering legislation
Establish appropriate AML procedures to risk assess and deter money laundering
Other regulatory requirements:
Professional Indemnity Insurance
In order to obtain a Practising Certificate, they must have a minimum level of Professional Indemnity Insurance (PII):
If gross fee income is less than £800,000 the minimum cover is two and a half times gross fee income (minimum £250,000)
Otherwise, the minimum is £2 million
Data Protection
They must register as a data controller with the Information Commissioner’s Office (ICO) under data protection legislation
We have just received a repayment into our bank account from HMRC for £45,700. Your recent letter suggested that we would receive £15,700. This increase is great news and means that we can now buy the new van that we need.’
Explain what actions you should immediately take in response to the email from Spanner Ltd.
Immediate actions to be taken
Check the client files to establish the correct amount of repayment due.
Contact the client to inform them whether this is an HMRC error and advise them not to spend the money
Check the engagement letter to see if there is authority to advise HMRC of the error, and if there is then inform HMRC of the error
If there is no authority, then ask the client for authority to inform HMRC or ask the client to inform HMRC
Warn the client of the possible consequences of a refusal, interest and penalties, criminal prosecution
Notify the client that if Spanner Ltd still refuses, the firm should cease to act.
Document the action taken and advice given to the client
Examiner’s comments
‘I heard that Jade from your office, who usually looks after my tax affairs, has been seconded to HMRC for six months. Please ask her while she is there to look into my tax affairs and compare them to some other people’s with similar income and investments, so that I can make more tax savings.’
Identify three fundamental principles that are threatened if Jade does what Luke requests. Explain the safeguards that should be put in place to remove any conflict of interest arising from Jade’s secondment to HMRC.
Fundamental principles threatened
Confidentiality
Objectivity
Professional behaviour
Safeguards
Whilst working for HMRC, Jade should not be involved in matters relating to (the seconding firm or) clients that she represents.
Following the end of the secondment, Jade should not be involved in the affairs of any taxpayer involved with at HMRC for a significant period.
You have been asked to look at the following three issues received by email from colleagues:
One of the managers in the tax department emailed to let you know that there is a new client, Daveth Tarly. The manager asked what actions need to be taken by your firm in relation to anti-money laundering procedures for Daveth.
A new trainee, Romesh, is concerned about some unusual transactions on a client’s bank account. Romesh asked both a senior colleague and the client about these transactions but was not satisfied with the answers. Romesh intends to discuss these transactions again with the client in the next couple of days. He is also concerned about any consequences for himself if he does not deal with this matter correctly.
The firm’s Data Protection Officer believes that too much information is being kept about former clients. He asked that all records relating to former clients, including records of client identification, be destroyed
Explain the correct anti-money laundering procedures to be undertaken in each of the three situations and state any actions that should be taken by the MLRO
Anti-money laundering procedures in relation to a new client
The following anti-money laundering procedures must be undertaken in relation to the new client:
Carry out due diligence on the client
Verify the identity of the new client and maintain evidence of the identification.
Disclosure of a suspicion of money laundering
The colleague should be advised not to discuss the internal report/potential disclosure to National Crime Agency (NCA) with the client as this is tipping-off, which is a criminal offence.
If a person is found guilty of tipping off there can be an unlimited fine and/or a sentence of up to two years.
The MLRO needs to consider whether there are reasonable grounds for knowledge or suspicion of money laundering. If so, the MLRO needs to submit a suspicious activity report (SAR) to the NCA.
Data protection and old clients
Data cleansing must be done at the appropriate time. Records of client identification must be kept for five years after the termination of the engagement and, records of transactions with a former client must be kept for five years after the transaction is complete.
The colleagues’ uncertainty regarding money laundering procedures may lead the MLRO to consider whether further training is required for all staff.
You work for a large firm of ICAEW Chartered Accountants and are currently helping the money laundering reporting officer (MLRO). Your firm had annual UK revenue of £10 million in 2023/24 and is expecting UK revenue of £11 million in 2024/25
As a firm of ICAEW accountants my firm will be within the anti-money laundering regulated sector and will therefore need to take the AML levy into consideration. This levy has applied from 2023/24 if a firm is of a sufficient size.
The levy in 2024/25 is based on the size of a firm based on its annual UK revenue on 2023/24 and as my firm has £10 million of revenue it will be classified as small. Consequently, no annual levy will be due.
Once my firm’s annual UK revenue exceeds £10.2 million in a tax year, it will be considered medium and will start paying the levy in the next tax year. In 2024/25, my firm’s annual UK revenue is expected to be £11 million and so the levy will be due for 2025/26 and will be £10,000.
You are an ICAEW Chartered Accountant working in practice. Your manager has asked you to review the following wording on the firm’s website for compliance with the Standards for Tax Planning in Professional Conduct in Relation to Taxation:
Your firm’s website states:
Come to us for all your tax planning needs. We offer various schemes from a generic scheme to a scheme tailored to your individual needs. We can help you with appropriate tax avoidance schemes which can reduce your tax liability to nil in most circumstances. We promise no risk of challenge from HMRC as our schemes follow the law.
Your manager stated:
Although our schemes follow the strict letter of the law it is arguable whether they follow the spirit of what Parliament intended. For example, one scheme has 15 steps, most of which are not for any real commercial reason but enable the taxpayer to get around what the legislation is supposed to do. HMRC takes a different view of the law for some of the schemes but as there is no case law, it is merely HMRC’s opinion.
Explain why your firm’s tax planning schemes do not comply with the Standards for Tax Planning in Professional Conduct in Relation to Taxation. Use three of the Standards to support your explanation.
Tax planning arrangements
Members must not create, encourage or promote tax planning arrangements or structures that
set out to achieve results that are contrary to the clear intention of legislation/Parliament) in enacting relevant legislation and/or
are highly artificial/contrived and seek to exploit shortcomings within the relevant legislation.
Client Specific
Tax planning must be specific to the particular client’s facts and circumstances. The generic/one size fits all plans are not permitted.
Clients must be alerted to the wider risks and the implications of any courses of action.
The information refers to a few more ‘tailored’ plans: it is possible that these will comply with this Standard if they are properly client specific.
Lawful
Tax planning should be based on a realistic assessment of the facts and on a credible view of the law.
The requirement to advise clients on material uncertainty in the law (including where HMRC take a different view) applies even if the practical likelihood of HMRC intervention is low. Stating there is no risk of the plan being challenged by HMRC is clearly not true.
Members should consider taking further advice appropriate to the risks and circumstances of the particular case, for example where litigation is likely.
Examiner’s comments
ou are an ICAEW Chartered Accountant working for a firm of ICAEW Chartered Accountants. Whilst performing tax work at Marquez Ltd, an audit and tax client of your firm, you were approached by Karen, a member of the finance department. Karen is a trainee ICAEW Chartered Accountant, who recently noticed that a large amount was entered into Marquez Ltd’s cash account as a VAT receipt. This was an unusual transaction as Marquez Ltd usually pays VAT to HMRC.
Karen asked the finance director, Craig, if she could look at the bank statements to verify the receipt.
Karen told you:
I am not convinced that this receipt relates to VAT. Craig became annoyed when I asked about the transaction and told me not to worry about it. He did not show me the bank statements and insisted that I must not mention this to any other member of staff, as it relates to a project that is not yet public knowledge. He warned me that any breach of trust could have a negative impact on my career at Marquez Ltd.
Requirement
Identify the threats faced by Karen as a result of her conversation with Craig and explain the actions that both you and your firm may need to take as a result of this disclosure by Karen.
The types of threat that Karen is subjected as a result of the conversation with Craig are:
Self-interest threat
Intimidation threat.
The actions that you should take are:
Document the discussion with Karen
Review both the cash account and bank statements to determine whether the amount relates to VAT
Ask Craig about the unusual transaction to determine the relevant facts
Document your discussions with Craig
If you are not satisfied by the disclosure by Craig and suspect money laundering, you should:
Make an internal report to your firm’s MLRO
Treat sceptically any other assertions made by the finance director
The MLRO as the firm’s representative should then:
Assess the information contained in the internal report
If relevant sent a suspicious activity report to the National Crime Agency
Avoid notifying Karen nor the finance director if you or the firm take any action in relation to anti-money laundering, as tipping off is a criminal offence
You work for Salt LLP, a small firm of ICAEW Chartered Accountants. Each of the three individuals below has asked to become a personal tax client of Salt LLP:
Aphra, a director of Limax Ltd. Limax Ltd is a local accountancy firm and is tendering for some of the same work as Salt LLP.
Bela, a property owner. Bela owns the office premises which Salt LLP rents.
explain why Salt LLP should refuse to act:
for Aphra
for Bela
Each potential client presents Salt LLP with a conflict of interest.
Any such conflict will threaten the firm’s objectivity.
A professional accountant is required to take reasonable steps to avoid, identify and resolve such conflicts. If a conflict cannot be managed acceptably, this will mean refusing to take on an engagement.
The ICAEW Code and Professional Conduct in Relation to Taxation give examples of situations which may give rise to a conflict. These include:
A client in competition with the firm. Aphra’s business is in competition with Salt LLP. This means that Aphra’s interests conflict with those of Salt LLP.
Financial involvement with a client. Bela, as landlord, is financially involved with Salt LLP.
Identify the safeguards which Salt LLP should consider putting in place if the firm decides to act for both Cal and Deborah.
Cal, who is divorcing Deborah. Deborah is already a client of Salt LLP
Acting for both parties to a divorce, as Salt LLP would if Cal became a client, presents a conflict of interest.
Both Cal and Deborah should be made aware of this, and their consent should be obtained.
Appropriate safeguards would include:
Use of separate engagement teams
Confidentiality procedures to prevent access to information by the other team (‘ethical walls’)
Clear guidelines and agreements for members of the engagement team(s) on security and confidentiality
Regular review of the application of safeguards by an independent senior individual
If the conflict cannot be managed sufficiently by means of safeguards, Salt LLP should refuse or withdraw from the engagement.
State how the minimum level of professional indemnity insurance (PII) for Sven is determined under ICAEW’s PII regulations.
The minimum level of PII that should be held by Sven is as follows:
If gross fee income is less than £800,000, the minimum level of PII must be
Two and a half times gross fee income
With a minimum of £250,000
Otherwise, the minimum is £2 million.
Sven has just received a phone call from Marina. Trustees in bankruptcy have been appointed to deal with the personal and business affairs of Marina’s husband, David. These affairs include a business partnership between David and Marina. Last week, as required by the courts, Sven handed a box of papers to the trustees in bankruptcy that relate to the partnership. The following is an extract of the call from Marina to Sven:
“I am furious with you. The box of papers that you handed to the trustees in bankruptcy contained three confidential documents relating to my personal tax affairs – they are nothing to do with the partnership. I intend to make a huge claim against your business for giving my private papers to somebody else and let all of the local newspapers know about it. This will ruin you. The only way to avoid ruining your business is for you to make me an immediate payment of £150,000.”
Following the alleged breach of confidentiality, explain:
the types of threat to which Sven is subjected; and
the actions that Sven should take as a result.
The types of threat that Sven is subjected to as a result of the phone call from Marina are:
Self-interest threat; as it may be financially beneficial to pay the £150,000 rather than to receive a PII claim. Bad publicity may affect Sven’s business if clients change advisers.
Intimidation threat; the phone call from Marina may deter Sven from acting objectively and instead coerce him into making an immediate payment so that the issue is resolved quickly.
The actions that Sven should consider taking are:
Make a file note of the telephone call for use in any future
Contact the trustees in bankruptcy to check whether Marina’s assertions are true
Resign as Marina’s adviser and inform HMRC of the resignation
Do not pay Marina
If Marina’s assertions are true then Sven should consider contacting:
His PII provider
A legal representative
His regulatory body ie, ICAEW
ICO to notify a breach of security of data within 72 hours of the breach coming to light
You are a newly qualified ICAEW Chartered Accountant working for Morton LLP, a firm of ICAEW Chartered Accountants. Throughout your training you have undertaken tax compliance work for Pitt Ltd, a client of your firm. Pitt Ltd is one of the Escoda Ltd group of companies. Escoda Ltd is not a client of your firm. You have built a good working relationship with Maya Rider, the finance director of Pitt Ltd.
Morton LLP has recently been engaged by Pitt Ltd to look at the impact of some problematic contracts on the estimated tax-adjusted trading losses of the company. You have been asked to produce a report.
At a meeting yesterday you told Maya that the preliminary findings show Pitt Ltd’s tax-adjusted trading losses will be increased by between £600,000 and £900,000. You cannot be more accurate until you complete your report at the end of next week.
Maya is now on holiday. She gave you her mobile number in case you need to contact her whilst she is away. Today you received an email from the Escoda Ltd group finance director. The email included the following:
‘Maya mentioned that you are producing a report on potential increased tax losses. Please could you let me know when your report will be ready. I would ideally like a draft copy to take to a meeting with the bank tomorrow. Maya is not able to attend as she is on holiday but mentioned that trading losses might increase by as much as £400,000. If this is the case, it could have an impact on a loan application we are making for the group.’
You are a little concerned that the increased loss mentioned in the email differs from your preliminary findings. You are not sure how to respond to the email.
Requirements
Requirement
Explain:
the fundamental principles that may be under threat in this situation; and
the actions that you should take.
undamental principles
The following fundamental principles may be under threat:
Confidentiality – as the engagement is with Pitt Ltd and not Escoda Ltd
Objectivity – loyalty to Maya should not override professional judgement. A familiarity threat may exist because of my relationship with Maya, or an intimidation threat in relation to the group FD
Integrity – one should always be honest in one’s professional relationships. I need to consider whether to respond just to the query re the date of the report, or let the group FD know about the extent of the potential losses
Professional behaviour – by disclosing the extent of the losses I may be protecting the reputation of my firm (subject to any potential confidentiality issues) I will need to ensure that I behave professionally in relation to Maya being on holiday.
Professional competence – if I were to try to hurry the completion of my report.
Actions
The actions I should take include:
Reviewing the letter of engagement to find out whether information can be disclosed to the main group board
Writing an email to the group FD that states when the report will be completed.
Contacting Maya to determine how the misunderstanding arose. (However, I need to be mindful of the fact that Maya is on holiday. If Maya does communicate on work matters whilst away, I need to ensure that any communication is formal.)
Telling Maya that I cannot be involved in providing misinformation
Asking Maya to rectify the information, or give me permission to do so
Making a written document of all information and action taken
Advise manager/partner re the situation for advice
Contacting the ICAEW helpline for confidential advice
Examiner’s comments
