Ken Siong Technical Director International Ethics Standards Board for Accountants (IESBA) SS/288 Our ref 529 Fifth Avenue, 6th Floor Sylvia Smith Contact New York, NY 10017 United States of America 03 February 2015 Dear Mr Siong Consultation Paper: Improving the Structure of the Code of Ethics for Professional Accountants We appreciate the opportunity to comment on the above Consultation Paper issued by the International Ethics Standards Board for Accountants (IESBA or the Board). We have consulted with, and this letter represents the views of, the KPMG network. Our overarching comments are set out below. The appendix to this letter provides our responses to the specific questions posed in the Consultation Paper. We are supportive of the considerations set out in the Consultation Paper, including restructuring and reorganising the content and layout of the Code as well as the clarification and simplification of the language. We believe this approach is likely to achieve the of improving IESBA’s aims the usability and enforceability of the Code. We consider this to be particularly important in jurisdictions in which the wording of the Code is imported directly into laws and regulations. In view of the stated objectives, we recognise the benefits of issuing the provisions of IESBA’s the Code as International Standard(s) on Ethics. We believe that such a rebranding approach would not preclude the continuing consideration and reference to these standards in totality as the Code of Ethics for Professional Accountants. We consider it helpful to retain reference to a which clearly establishes fundamental principles related to the overarching responsibility “code”, of acting in the public interest and which underpins the activities of the accountancy profession as a whole. In particular, we believe that in the form of a code, the content achieves a cohesive and meaningful approach to addressing professional ethics, supported by the Conceptual Framework, to guide all accounting professionals in discharging their various duties.
Ken Siong Technical Director International Ethics Standards Board for Accountants (IESBA) 529 Fifth Avenue, 6th Floor New York, NY 10017 United States of America 03 February 2015 Our ref SS/288 Contact Sylvia Smith Dear Mr Siong Consultation Paper: Improving the Structure of the Code of Ethics for Professional Accountants We appreciate the opportunity to comment on the above Consultation Paper issued by the International Ethics Standards Board for Accountants (IESBA or the Board). We have consulted with, and this letter represents the views of, the KPMG network. Our overarching comments are set out below. The appendix to this letter provides our responses to the specific questions posed in the Consultation Paper. We are supportive of the considerations set out in the Consultation Paper, including restructuring and reorganising the content and layout of the Code as well as the clarification and simplification of the language. We believe this approach is likely to achieve the IESBA’s aims of improving the usability and enforceability of the Code. We consider this to be particularly important in jurisdictions in which the wording of the Code is imported directly into laws and regulations. In view of the IESBA’s stated objectives, we recognise the benefits of issuing the provisions of the Code as International Standard(s) on Ethics. We believe that such a rebranding approach would not preclude the continuing consideration and reference to these standards in totality as the Code of Ethics for Professional Accountants. We consider it helpful to retain reference to a “code”, which clearly establishes fundamental principles related to the overarching responsibility of acting in the public interest and which underpins the activities of the accountancy profession as a whole. In particular, we believe that in the form of a code, the content achieves a cohesive and meaningful approach to addressing professional ethics, supported by the Conceptual Framework, to guide all accounting professionals in discharging their various duties.