4 February 2015 Mr. Ken Siong IESBA Technical Director International Ethics Standards for Accountants 545 Avenue, 14th Floor New York, New York 10017 USA Email: KenSiong@ethicsboard.org Consultation Paper - Improving the Structure of the Code of Ethics for Professional Accountants Dear Mr. Siong, BDO International Limited (BDO) is pleased to have the opportunity to comment on the International Ethics Standards Board for Accountants (IESBA or Board) Consultation Paper on Improving the Structure of the Code of Ethics for Professional Accountants. We recognise that there has been a desire, based on stakeholder feedback, to restructure the Code in order to improve its usability and we therefore welcome the proposed changes. We recognise the arguments detailed in the Consultation Paper regarding the drivers for this project and understand views of some stakeholders that changes are needed to increase confidence in the Code, particularly in the eyes of regulators. However, from the point of view of our own network, we have spent considerable time and effort incorporating the code’s principles into our methodology, training and control environment in a robust and straightforward manner and do not feel as strongly that a complete overhaul is required. Having said that, the Consultation Paper is a well thought out plan, which has the potential to achieve its objectives. We do strongly note, however, the enormity of the task at hand, particularly as there is no intent to change the underlying substance and principles. We recognise that many regulators and standard setters have done similar codifications and have found the process to be difficult and time consuming. It should also be noted that it might have consequential effects on other codes and standards. To this point, extreme diligence is required, as simple changes to the language and structure of the Code could cause unintended changes. Therefore, we urge you not to underestimate the work involved, the importance of wide-consultation and the eventual timetable that firms will need to rewrite methodologies, tools and training to be consistent with the revised Code. With this in mind, our view is that the anticipated timescale is ambitious. The following are our responses to the request for specific comments in the Explanatory Memorandum. Do you believe that the approach outlined in this Consultation Paper, as reflected in the Illustrative Examples, would be likely to achieve IESBA’s objective of making the Code more understandable? If not, why not and what other approaches might be taken?
4 February 2015 Mr. Ken Siong IESBA Technical Director International Ethics Standards for Accountants 545 Avenue, 14th Floor New York, New York 10017 USA Email: KenSiong@ethicsboard.org Consultation Paper - Improving the Structure of the Code of Ethics for Professional Accountants Dear Mr. Siong, BDO International Limited (BDO) is pleased to have the opportunity to comment on the International Ethics Standards Board for Accountants (IESBA or Board) Consultation Paper on Improving the Structure of the Code of Ethics for Professional Accountants. We recognise that there has been a desire, based on stakeholder feedback, to restructure the Code in order to improve its usability and we therefore welcome the proposed changes. We recognise the arguments detailed in the Consultation Paper regarding the drivers for this project and understand views of some stakeholders that changes are needed to increase confidence in the Code, particularly in the eyes of regulators. However, from the point of view of our own network, we have spent considerable time and effort incorporating the code’s principles into our methodology, training and control environment in a robust and straightforward manner and do not feel as strongly that a complete overhaul is required. Having said that, the Consultation Paper is a well thought out plan, which has the potential to achieve its objectives. We do strongly note, however, the enormity of the task at hand, particularly as there is no intent to change the underlying substance and principles. We recognise that many regulators and standard setters have done similar codifications and have found the process to be difficult and time consuming. It should also be noted that it might have consequential effects on other codes and standards. To this point, extreme diligence is required, as simple changes to the language and structure of the Code could cause unintended changes. Therefore, we urge you not to underestimate the work involved, the importance of wide-consultation and the eventual timetable that firms will need to rewrite methodologies, tools and training to be consistent with the revised Code. With this in mind, our view is that the anticipated timescale is ambitious. The following are our responses to the request for specific comments in the Explanatory Memorandum. Do you believe that the approach outlined in this Consultation Paper, as reflected in the Illustrative Examples, would be likely to achieve IESBA’s objective of making the Code more understandable? If not, why not and what other approaches might be taken?
BDOResponse_IESBAConsultationPaper-ImprovingtheStructureoftheCodeofEthicsforProfessionalAccountants_P.docx