May 21, 2019
By: Erica Steenwijk, Policy Advisor, Netherlands Institute of Chartered Accountants and Stathis Gould, Deputy Director, Professional Accountants in Business, IFAC
Being a professional accountant requires much more than professional competence in technical matters. The actions or inactions of accountants, whether they are working in business, advisory or audit, influence decisions and actions of others, and contribute to the moral bearing of organizations and societies.
Accountancy, as with other professions, is in fact, a social and moral practice.
For an accountant to be a trusted advisor or business partner, professional ethics is fundamental. Professional integrity should be valued for bringing credibility to decision making and safeguarding the interests of stakeholders. Doing the right thing is as important as being a technical expert. To this end, accountants in business need to be conscious of how they influence ethical business culture. Professional accountancy organizations need to think innovatively on how to support them in discharging their ethical responsibilities.
The reality is that making the right call is often not straightforward. Few ethical dilemmas are black or white, and many could involve different perspectives and choices. In business, making a decision for the benefit of one group of stakeholders can sometimes be to the detriment others’ interests. Often there are important moral considerations to take into account, such as in relation to the natural environment, or how value is distributed.
Accountants working in business and the public sector face a range of ethical dilemmas on a frequent basis. Recognizing and tackling dilemmas in real time is a significant part of being a professional. Consequently, it is important for the profession to provide adequate support to accountants to help them enhance their moral awareness, competence, and courage.
Recognizing that their members face ethical challenges and moral questions in their everyday work practices, The Royal Netherlands Institute of Chartered Accountants (NBA) uses a “moral intervision model” developed by the Nyenrode Business University in Breukelen. It is an action-based approach comprising six key questions and steps that are addressed in a group setting to help accountants reflect on the ethical issues they face at work.
A framework for moral prudence
The moral intervision model is a practical and simple framework that helps people decide what or what not to do in situations where they are required to make a moral assessment. The approach is designed to help with everyday situations, and help to apply professionalization, learning and self-improvement.
It is based on “peer supervision” which means that dialogue in a group is an important element to developing moral prudence and effectively dealing with ethical issues. Engaging with others is likely to improve one’s ethical thinking by helping to view an issue from different perspectives. A professional accountancy organization could enable this approach by providing workshops or group sessions involving members or use the model as a tool to help frame a dialogue on a telephone support line.
Alternatively, an accountant in business could convene a small group of trusted colleagues to facilitate him/her in going through the steps and addressing the questions until a conclusion and decision has been reached. A group of five to eight participant peers generally works best.
The role of the participants is to offer perspectives and insights into the dilemma while addressing the six questions. Doing so helps to develop different ways of thinking about the issue, alternative ways of behaving, and ultimately helps an individual come up with a decision or action.
The Six Key Steps in the Moral Intervision Model
1. What am I required to make a decision on?
This involves outlining the nature and context of the dilemma including why it is a dilemma for the individual involved. It is important to describe the dilemma from a personal perspective, detail what action the individual is considering taking, or not taking (not doing something can, in certain cases, also be considered an action), and the options they are considering and not considering.
2. Who are the stakeholders affected?
Taking stock of all the parties, individuals, and organizations involved whose rights or interests are affected by the decision.
3. What do the rules of professional practice, business or governance codes, or other binding laws and regulations say?
There are frames of reference that may be helpful in forming a judgment and decision-making, including:
· The International Ethics Standards Board for Accountants’ International Code of Ethics for Professional Accountants (including International Independence Standards),or Code of Ethics from the IFAC member body should be a primary reference point. The five principles of the Code need to be considered as well as any specific safeguards that can be actioned. Safeguards are the actions, either individually or in combination, that an accountant can take to reduce threats to compliance with the fundamental principles to an acceptable level. Not all threats can be addressed by the application of safeguards.
· The organization’s code of conduct and values. Many organizations have an employee code of conduct or ethics.
· Relevant laws and regulations that need to be considered, including relevant case law, and guidance (although if an action is legal it does not necessarily mean it is morally right hence why the approach the model is focused on making a moral assessment).
· Codes of best practice such as a corporate governance or director’s code.
4. Which arguments can be made for the possible decisions and alternative courses of action?
To establish a position – to do or not do something – one needs to be able to raise arguments for it that are powerful enough to persuade others. One must also bear in mind any arguments that may be raised against the position. The point is not to neutralize such counterarguments, but rather to show that they were taken into consideration and be able to state in a conclusion how one intends to do justice to those counterarguments. It is helpful to set out the arguments in favor and against taking a particular course of action. The Royal NBA uses Muel Kapteijn’s model of Neutralization Techniques to outline common excuses to defend certain situations, which might not in fact be substantial considerations or arguments. Typical excuses or “neutralization techniques” include: distorting the facts (“it is not the truth”), negating the norm (“it is not decisive”), blaming the circumstances (“it is beyond my control”), and hiding behind oneself (“it is a lack of self-control” or “I really didn’t think I was doing anything wrong at the time”).
5. What is my conclusion after discussing the dilemma with my group members and answering all the questions above?
Once the arguments in favor and against have been exchanged and weighed, a clear conclusion can and must be formulated. Specify which arguments tipped the scales. Consider if it is possible to formulate a creative solution that does justice to as many arguments (for and against) as possible.
In doing so, explore whether there would be a way to mitigate any negative consequences to certain stakeholders. The consequences should be included in the list of arguments that were judged to be less important.
6. What is my individual decision or action? Am I going to actually do it?
Finally, it is important to address the key questions, “can I live with the consequences of my decision?” and “am I going to follow through with the decision?”
A final question is to consider what action you would take if the situation was in the public domain, and whether your actions might be different in a situation of public scrutiny.
A key aspect of this model is that it is culturally neutral although the ultimate decisions and actions an accountant might take can be affected by culture and social norms. This might lead to a conclusion that an ethical situation is “acceptable” despite not being morally prudent. Consequently, ethical training for accountants should explicitly consider how to deal with cultural considerations and social norms where they can inhibit accountants’ ability to uphold their ethical duty.