Code of Ethics update: professional behaviour in practice

ICAEW’s updated Code of Ethics comes into effect on 1 July. One of the key revisions is a rewording of the provisions on professional behaviour to recognise the changing world of work and how members’ professional lives are evolving.

The new wording aims to clarify ICAEW’s expectations of how members should behave as professionals, and the context in which they would be considered to be acting in their professional lives.

It also now includes a ‘reasonable and informed third party’ test as part of the expectations of a member’s conduct. This means that a member is measured against the expectations of somebody who has the knowledge and experience to evaluate the appropriateness of a member’s conduct objectively and impartially.

“The changes represent a clarification of the expectations that have always been there,” explains Sophie. “And the vast majority of our members already behave in this way. But we hope that making it clearer what behaviours are and aren’t acceptable will be positive for members, as well as helping to demonstrate more widely that this is what people can expect when they deal with a Chartered Accountant.”

Building trust

“The origin of these changes goes back to discussions in ICAEW’s Council about trust in the profession, and the fundamental principles in the Code of Ethics,” explains Sophie. “In particular, it was felt that the Code’s section on professional behaviour needed to better reflect the modern world.”

Most of the focus was on the wording of paragraph 115.1 A2, which is application material designed to help members comply with the requirements in the Code. This paragraph previously stated:

“The concept of professional behaviour implies that it is appropriate for professional accountants to conduct themselves with courtesy and consideration towards all with whom they come into contact when performing their work.”

“The general feeling was that this was dated and needed refreshing,” says Sophie. “And from discussions with professional standards staff, in particular the Conduct Department, we identified that this wording wasn't always capturing or adequately addressing the types of misconduct we're seeing.”

To tackle these concerns, new wording was developed, and consulted on, to help members understand the expectations placed upon them, in particular their conduct in their professional lives. After incorporating useful feedback from the consultation, the wording was approved by ICAEW Council and published in April 2025, to come into effect on 1 July 2025.

Providing clarity

The overarching requirement in terms of professional behaviour is set out in Subsection 115 of the Code of Ethics. This requires members to comply with relevant laws and regulations and avoid any conduct that they know or should know might discredit the profession. There is also an addition from the International Code of Ethics for Professional Accountants from July 2025 that members must behave in a manner consistent with the profession’s responsibility to act in the public interest.

To clarify the expectations of member’s personal conduct, the revised paragraph 115.1 A2 now reads:

“A reasonable and informed third party would expect that a professional accountant, in their professional life, treats others fairly, with respect and dignity and for example does not bully, harass, victimise or unfairly discriminate against others.”

“The guidance as it stood wasn’t always capturing the conduct we’ve been concerned about or setting out clearly for members our expectations for them as professionals,” says Sophie. “So, the new wording brings in the concept of what a ‘reasonable and informed third party’ would expect and includes specific reference to those expected behaviours.”

The concept of a ‘reasonable and informed third party’ is well understood and already features elsewhere in the code. “What that's referring to is someone who is objective and impartial, and understands both the context of a situation and what our profession does,” explains Sophie. “And I think that gives comfort to members that there is a reasonableness test built into this.”

“We've also moved from ‘courtesy and consideration’ to treating people fairly with respect and dignity,” she says. “That's not in conflict with ‘courtesy and consideration’, which is obviously something we’d still want to see, but it's making it clearer that our expectation is that you treat people in these positive ways.

“There’s also a non-exhaustive list of poor behaviours,” she adds. “These make it clear that if, in your professional life, you were to bully, harass, victimise or unfairly discriminate against somebody, that is something that could bring discredit to the profession.”

Professional life

The new wording now refers to your ‘professional life’ rather than those you come into contact with when performing your work. This clarifies that ICAEW’s expectations for how you conduct yourself apply to all of parts of your professional life.

“We felt the existing wording was too narrow,” explains Sophie. “It was written in a time when working meant you would probably be in an office for the majority of your work activities.

“But the way we work now is more fluid and there are many things we think are relevant to your life as a professional, including work social events, your social media posts, and activities you do from your home, rather than in the traditional workplace.”

“Since the Code was originally drafted, life has moved on, and people are working in very different ways,” adds Carrie. “So, using the term ‘professional life’ addresses the fact that being a Chartered Accountant is wider than just the work you do while sat in your office.”

Under the previous Code, a frequent question was what actually constitutes a person’s ‘work’? For example, people were unsure if it applied when they were doing voluntary work outside their day job. The rise of working from home also led to greater blurring between professional and private lives, and uncertainties about what was and wasn’t appropriate.

“The other big change has been a huge rise in use of social media inside and outside of work,” adds Carrie. “Many more people participate in social media now than they did when the Code was originally drafted and, because these interactions are so public, when you're looking at what might bring discredit to the profession, the potential for damage is far more significant. So, it's really important for our expectations to be clear and to evolve in response to what members do and the ways they work.”

What do the changes mean?

As well as clarifying expectations for members, the changes should assist firms in identifying conduct issues and understanding what they should be reporting to ICAEW under their Duty to Report Misconduct, as the professional body, in terms of unacceptable behaviour by members.

“From the conduct perspective, we believe the new wording better reflects how people work now,” says Carrie. “And that's really important in terms of the issues that are getting reported to us and in pulling together some of the areas where we’re seeing more cases.”

“We’ve been seeing cases where people have been rude or abusive for a while,” she adds. “But there will always be new things coming along. Changes during the COVID-19 pandemic, for example, raised the issue of professional behaviour when you're inside your home - such as whether you’re appropriately dressed or behaved when appearing online. These just weren't the sort of discussions we would have been having six or seven years ago because it wasn't in people's sphere of reference.”

“It all comes down to what we mean by professional life,” says Sophie. “And the boundaries between personal and professional life have been evolving because of the way we're working and the growing use of social media. So, the new guidance we’ve created to support these changes goes into more detail about what we mean by professional life.”

This guidance will help members understand the sorts of scenarios and expectations professional life covers, including when certain activities would be considered as within a Chartered Accountant’s professional life.

“For example, if you’re posting on social media and your professional status as an accountant is visible or identifiable then it's considered you've made that post in your professional life,” says Sophie. “So, for example it’s highly likely that your LinkedIn account, as your professional profile, means the posts you're making there are being made in a professional capacity and these standards apply.”

“The identifiable point is important,” adds Carrie. “People have multiple accounts, and you might be commenting on X but not necessarily saying you’re an accountant. However, someone would only have to do a search on your name to find out you’re a partner in an accountancy firm and, in some cases, your LinkedIn account may be linked to X or other platforms you use professionally or personally.”

“In general, our advice is to exercise caution and always stop and think about what you're posting, how you're saying it, and whether it could reflect badly on you as a professional,” she says. “Also, there’s the business perspective to consider, because you could be potentially alienating yourself from clients, or potential clients, if you’re making comments they might not agree with or don't like.”

“It’s also important to remember that it's not only your professional life that's relevant to ICAEW,” emphasises Sophie. “This new material in the Code is about our expectations for your professional life, but there is also the overarching requirement not to bring discredit to the profession and to comply with all relevant laws and regulations, and you can also bring discredit through the things you do in your private life.”

“Regardless of whether it's your professional or personal life, if you get a conviction or you've done something illegal, then it is likely to be a disciplinary matter,” she explains. “And, outside of this new wording, it's always been the case that if you’ve done something seriously offensive or harassing in your private life, that can also bring discredit.”

Be mindful

The updates to the Code of Ethics take effect from 1 July, and ICAEW is urging everyone to read the new wording on professional behaviour and familiarise themselves with the other revisions, including on the role and mindset expected of professional accountants, and the impact of technology.

“In terms of professional behaviour, it’s really a clarification, not a big change,” says Carrie. “Our expectations remain broadly the same, but we’ve made things clearer and we’re issuing more guidance to support members.”

“Our key message is that members need to be mindful of their behaviour, and of the requirements and guidance,” she stresses. “As professionals, we are rightly held to a higher standard and members need to take that into account and understand, and keep up to date with, their obligations.”

Further resources

• Guidance on boundaries between a member's personal and professional life
• Guidance on your duty to report misconduct