AUD300 Summary
Module 12 – Professional Ethics
SAICA CPC (code of professional conduct) has 3 parts:
PART A:
General applications of code
PART B:
CA in PUBLIC practice
PART C:
CA in BUSINESS
CPC
PART A: GENERAL APPLICATION OF THE CODE
Fundamental Principles:
Threats:
COPPI
1. Confidentiality
1. Self-interest threats
2. Objectivity
2. Self-review threats
3. Professional Competence & Due Care
3. Advocacy threats
4. Professional behaviour
4. Familiarity threats
5. Integrity
5. Intimidation threats
S
I
A
S
FUNDAMENTAL PRINCIPLES
Implies that auditor always have to act in straightforward, honest manner and may not be associated
with:
1. INTEGRITY
2. OBJECTIVITY

False information

Misleading reports

Cover up information

Or be part of committing or obscuring of information causing it to be misleading

CA must always remain objective IN EVERY SITUATION

Never compromise professional judgement because of bias, conflict of interest or any kind of
influence of others
Maintain professional knowledge and skill:

Attainment of professional competence

Maintenance of professional competence (Continuous Professional Development – attend
workshops, seminars conferences etc.)
3. PROFESSIONAL
COMPETENCE & DUE
CA needs to ensure that he and those under his supervision are continuously up to date to ensure clients
receive best service possible
CARE
If not up to date – CA may not accept engagement
CA not competent to perform required service, CA may not continue to perform service UNLESS:

There is someone available who is competent that can provide assistance to ensure appropriate
level of insurance is obtained
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AUD300 Summary
Module 12 – Professional Ethics
4. PROFESSIONAL

CA should always act in manner that his actions will not discredit profession
BEHAVIOUR

Thus acting in manner that reliable, informed 3rd party who has knowledge of all facts will reach
same conclusion

Professional behaviour situations:
Publicity,
CAs must be honest & truthful – therefore do not:
advertising &

solicitation
Make exaggerated claims for services they are able to offer, qualifications
they possess, or experience they have gained

Make disparaging references or unsubstantiated comparisons to work of
others
When preparing & authorising material that will be used in advertising, publicity,
cold calling & direct mailing – remember responsibility to profession & public
Content has to be OBJECTIVE & in GOOD TASTE
Advertisements may refer to basis on which fees for services are calculated –
may not state hourly or other charging rates
Multiple firms

CA may be member at more than 1 firm

CA may practise under different firm names – clearly state is – not
misleading

Clear distinction should be made between member who are qualified as CA
and those who aren’t to ensure AP Act is not contravened.
Signing
CA may not delegate responsibility of signing audit report, review report, other
convention for
certificates to any person who is NOT audit partner, or fellow director.
reports/
Certain circumstances allowed:
certificates

Emergencies of sufficient gravity arise, and

Full circumstances that gave rise to delegation is reported to client &
regulatory board
Audit, review, assurance report should reflect following:
Recruiting

Individual accountant’s full name

Capacity in which report is signed (e.g. Director/Partner)

Designation needs to be provided underneath (CA)

Name of CA’s firm

Employment MAY NOT be offered directly to potential employee will still
working at another CA firm WITHOUT informing employer first

CA is allowed to respond to advertisement out of his own free will, provided
he has INFORMED CURRENT employer of intentions
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AUD300 Summary
Module 12 – Professional Ethics
Responsibilities to
CA shall always conduct himself in manner which promotes co-operation & good
colleagues
relationships between members. Also extend same courtesy to non-members:

Promote co-operation and good relations between CAs

Assist fellow CAs in complying with this Code

Co-operate with appropriate disciplinary authorities in applying code

Not seek to displace another CA in client relationship by negative means

Not act in any way that reflects negatively on fellow CA’s

Extend same professional considerations to non-member where
professional relationship; same procedures for change in appointment
5. CONFIDENTIALITY
CAs should refrain from:

Disclosing confidential information acquired as result of professional/business relationships without
proper authority

Use confidential information acquired to his or 3rd party’s advantage
Signing of confidentiality agreements = NB (applies to CA and those under his supervision)
Confidentiality = NB, even after engagement is completed
May disclose information in following circumstances:
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
Required by law (e.g. court case)

Permitted by law & authorised by client / employer

Professional duty / right to disclosure & not prohibited by law:
o
Quality review conducted on company
o
Protect interest of CA when he is engaged in public proceedings
o
Compliance with technical standards & requirements of CPC
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AUD300 Summary
Module 12 – Professional Ethics
THREATS
1. SELF-INTEREST
THREATS
2. SELF-REVIEW
THREATS
CA or close family have direct financial or other interest in client
e.g. significant shareholding in company being audited e.g. 40% shares
CA has to review previous judgement or services rendered previously by himself or by another CA at the
same firm.
CA promotes opinion / position to point that subsequent objectivity may be compromised
3. ADVOCACY
THREATS
e.g. CA recommends a financial manager and then later has to audit the work of the person she
recommended
Close relationship, CA becomes too sympathetic to a situation
4. FAMILIARITY
THREATS
E.g. John needs to audit a firm. His wife is also a CA but was appointed at firm John as to audit as a
financial manager. Threat since John’s audit client is also source of their second income & employer of his
wife. He will not want to do anything to jeopardise his wife’s job.
5. INTIMIDATION
THREATS
CA may be deterred from acting objectively by threats, actual or perceived
E.g. You stumble upon an irregularity during audit – question the relevant person and that person
threatens you e.g. you will not make partner if you report the irregularity
DEALING WITH AN ETHICAL ISSUE ‘FRAMEWORK’:
Step 1: Identify the issue
Step 2: Identify the threats
Step 3: Identify the fundamental principles
Step 4: Consider the significance
Step 5: Implement safeguards
Step 6: If safeguards does not reduce risk to an acceptable level – take action
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AUD300 Summary
Module 12 – Professional Ethics
PART B: CAs IN PUBLIC PRACTICE
Professional
Appointment
Custody of Client
assets
Conflict of Interest
Second Opinions
CAs in Public
Practice
NEW:
Responding to noncompliance with Laws &
Regulations
Gifts & Hospitality
Lowballing
Marketing
Fees & other types of
remuneration
Referral Fees
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Contingency
Fees
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AUD300 Summary
Module 12 – Professional Ethics
EXAMPLES OF THREATS IN PUBLIC PRACTICE
(READ – NOT STUDY!)

Direct financial interest

Material indirect interest

Dependence on total fees (Enron)
1. SELF-INTEREST

Close business relationship
THREATS

Concern over losing client (Enron)

Potential employment by client

Contingent fees for assurance engagement

Loan/guarantee to/from client or directors/ officers of client

Having prepared the original data used to generate records for the subject matter of the engagement.

Being involved with financial systems design and implementation and then reporting on operation

Member of team previously director/employed by client in a position to exert a direct and significant influence
2. SELF-REVIEW
THREATS
over the subject matter.

Performing service that directly affects subject matter of assurance engagement

Discovering of a significant error during re-evaluation of work done
3. ADVOCACY

Promote shares/securities – then that client becomes assurance client
THREATS

Acting for client in litigation/resolving dispute with 3rd party

Member of team – close family with director of client

Member of team – close family with employee with influence on subject matter of engagement

Former partner of firm being director/employee with influence over subject matter of the audit

Long association of senior team member with client

Acceptance of significant gifts/ hospitality

Threat of replacement/ dismissal

Threat of litigation

Threat to reduce extent of work to reduce fees
4. FAMILIARITY
THREATS
5. INTIMIDATION
THREATS
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AUD300 Summary
Module 12 – Professional Ethics
Professional Appointment:
Before accepting client, specific engagement or replacing another CA – CA in public practice should determine if there are any
circumstances that may create threats to compliance with fundamental principles.
Threats should be evaluated

Safeguards should be applied
Client Acceptance

Threats
Safeguards
Threats to: Professional Behaviour &

Integrity
managers and those responsible for governance and bus

Client involvement in illegal activity
activities

Dishonesty

Questionable financial reporting practice
Engagement Acceptance
Self-interest Threats:

1.


Changes in professional Appointment
3.
Obtain understanding of nature of client’s business,
CA should only agree to provide those
complexity of operations, purpose, specific nature and
services he is competent to perform
scope of work
Determine if there’s any reason,
engagement
2.
Securing client commitment to improve corporate
governance practices or internal controls

Acquiring knowledge of industry/subject matters

Assigning sufficient competent staff

Using experts

Agreeing on realistic time frames

Complying with quality control policies and procedures

Discuss the client’s affairs fully and freely with the existing
professional or other, not to accept
accountant

Ask the existing accountant, preferably in writing, to provide
Communication with existing accountant
information on any professional reasons which should be
depends on:
known before accepting the appointment within a
o
Client’s permission
reasonable time
o
Legal or ethical requirements
Request permission (in writing) to
If communication with existing accountant is not possible, obtain
communicate with the existing
info about any possible threats by other means:
accountant. (NB! Existing accountant

Inquiries of 3rd parties
should not volunteer info without

Background investigations on senior management or those
permission)
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Obtain knowledge and understanding of the client, owners,
charged with governance
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AUD300 Summary
Module 12 – Professional Ethics
Conflict of interest:
CA in public practice may be faced with conflict of interest when performing professional service.
Threats are mainly to objectivity but other fundamental principles do also apply.
Threats
Safeguards
Threats to: Objectivity
If threats are INSIGNIFICANT:

competes directly with client; or


has material business relationship
notify client of firm’s business interest or activities = conflict, and
obtain consent to act

with direct competitor of client
notify all known relevant parties that you act for 2 or more
Conflict of interest
parties in conflict, and obtain consent
Threats to: Objectivity & Confidentiality 
notify client that you do not act exclusively for any one client in

provision of services, and obtain consent
performs services for clients whose
interest are in conflict; or

clients are in dispute with one
If threats are SIGNIFICANT:
another

use separate engagement teams

procedures to prevent access to information

guidelines to teams w.r.t issues of security and confidentiality

confidentiality agreements

regular review of application of safeguards by senior
management
Second Opinions:
2nd Opinions
CA is asked to express a second opinion.
Threats
Safeguards
Threats to: Compliance with Fundamental

seeking client permission to contact existing accountant
Principles

describe limitations surrounding any opinion in

provision of second opinion on
application of accounting, auditing,
communications with client, and

providing existing accountant with copy of opinion
reporting or other standard or principles
to specific transactions or circumstances

by or on behalf of company or entity not
an existing client
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AUD300 Summary
Module 12 – Professional Ethics
*(NB!!!!!!)
Lowballing
Fees & Other types of remuneration:
Definition
Threats
Safeguards

Charging lower tariff
Self-interest threat to professional

than previously
competence
engagement, i.e. basis on which fees are
charged or charged by

charged and services covered

fee that is quoted is so low that
another accountant
it may be difficult to perform
But still comply with
engagement in accordance
technical standards
with applicable technical

making client aware of terms of
assigning appropriate time and qualified
staff
Generally used for certain
Self-interest threat to objectivity
types of non-assurance

the nature of the engagement
engagement

the range of possible fee



an advance written agreement with the
client w.r.t basis of remuneration

amounts
*(NB!!!!!!)
Contingency Fees
standards
disclosure to intended users of work
performed and basis of remuneration
the basis for determining the

quality control policies and procedures
fee

review by an objective 3rd party of work
performed
whether outcome or result
will be reviewed by an
Commission/ referral fees
independent 3rd party
Examples:
Self-interest threat to objectivity

pay referral fee to
and professional competence and
obtain client
due care

disclosing to the client any arrangements to
pay a referral fee

receive from 3rd party
for work referred (e.g.


disclosing to the client any arrangements to
receive a referral fee

obtaining in advance agreement from client
software vendor)
for commission arrangements in connection
receive referral fee for
with 3rd parties
referring continuing
client to another
professional
accountant
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AUD300 Summary
Module 12 – Professional Ethics
Marketing Professional Services:
Threats
Safeguards
Self-interest threat to compliance with
Consult Regulatory Board or SAICA for the appropriateness of
professional behaviour if:
proposed form of advertising
Marketing Professional Services

Services, achievements or products
marketed in a way inconsistent with
principles

Should be honest and truthful and should
not:
o
make exaggerated claims for
services offers, qualifications
possessed or experience gained, or
o
make disparaging references to
unsubstantiated comparisons to the
work of another
Gifts & Hospitality
Gifts & Hospitality:
Threats
Significance

Depends on:

Self-interest threat to objectivity if a gift
from a client is accepted
1.
Nature
Intimidation threat to objectivity may
2.
Value
result from possibility of such offers being
3.
Intent behind offer
made public
Offers made in normal course of business will not pose a significant threat, e.g. Audio CD from record company audited.
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AUD300 Summary
Module 12 – Professional Ethics
Custody of client assets:
Should not assume custody of client monies or assets, unless:
permitted by law

in compliance with any additional legal duties imposed
Custody of client assets

Threats
Safeguards

Self-interest threat to professional

separately from personal or firm assets
behaviour

use such assets only for the purpose for which they are

intended
Self-interest threat to objectivity

at all times, be ready to account for those assets, any
income, dividends or gains generated to entitled persons

comply with all relevant laws and regulations
When CA in course of providing professional services is entrusted with client monies or property, CA shall:
Monies
1.
Other property
Keep monies in a separate bank account (separate
1.
from CA’s own bank account
2.
3.
Maintain records to ensure that property can be
identified as being property of the client
Appropriately designate such account (account in
2.
Safeguard documents against unauthorized use in
name of CA of client)
cases where property is in form of documents of title
Deposit client monies directly without delay to credit
to money
of such account
Objectivity – all services
Objectivity – All services
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Threats
Safeguards
When you are not independent in mind or

withdrawing from the engagement team
appearance or you have a direct relationship

supervisory procedures
with someone at management level,

Terminating business/ financial relationship giving rise to
consider the following safeguards
threat

Discuss issue with higher levels of management within firm

Discuss issue with those charged with governance at client
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AUD300 Summary
Module 12 – Professional Ethics
Independence – Assurance Engagements
Independence of mind
Independence in appearance

To provide opinion

Avoid fact & circumstances

Free of influences

Which would make reasonable/informed third party

Professional judgment with integrity, objectivity and
believe

scepticism
Integrity, objectivity and professional scepticism had
been compromised
Responding to non-compliance with Laws & Regulations

CAs must always act in public interest

Objective of responding to non-compliance with L&R:
o
Compliance with fundamental principles: integrity & professional behaviour
o
Alerting management / TCWG to:
o

Enable them to rectify, remediate / mitigate consequences of non-compliance OR

Prevent non-compliance where it has not yet occurred
Take further action as appropriate in public interest
Generally CA not required to comply with this section w.r.t. matters that are clearly inconsequential on client, stakeholders &
general public
This section excludes personal misconduct unrelated to business activities of client
APPROACH:
1. Obtaining
understanding of matter
2. Addressing matter
3. Determining wheter to
disclose matter to
appropriate authority
4. Documentation
1. Obtain understanding of matter:

Obtain understanding of non-compliance / suspected non-compliance
o
Whether in course of performing engagement OR
o
Information provided by other parties

CA not expected to have level of knowledge that is greater than what is required to undertake engagement

Confidential consultation with others in firm, network firm / professional body permitted depending on nature &
significance of matter

CA should discuss matter with appropriate level of management
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AUD300 Summary
Module 12 – Professional Ethics
2. Addressing matter:


Advise management / TCWG to take appropriate action:
o
Rectify, remediate / mitigate consequences of non-compliance
o
Prevent non-compliance where it has not yet occurred
o
Disclose mater to appropriate authority where required to do so by law/considered in public interest
Component auditor shall consider communicating actual/suspected non-compliance with Engagement partner unless
prohibited by law/regulation to do so

Determining whether further action is needed assess:
o


Appropriateness of response by management / TCWG
Further actions:
o
Disclose matter to appropriate authority it not required to do so by law
o
Withdrawing from engagement
CA shall on request of successor accountant provide all info regarding actual/suspected non-compliance
3. Disclose matter to appropriate authority:

Precluded if doings would be contrary to law/regulation

Deciding whether or not to disclose:
o

Consider actual/potential harm cause by matter to investors, creditors, EEs, general public
Decision also influenced by:
o
Whether there is appropriate authority able to receive & deal with information
o
Whether robust & credible protection exist from civil, criminal / professional liability / retaliation
o
Whether there are threats to physical safety of any person
4. Documentation:
Document:

How management / TCWG have responded to matter

Courses of action considered, judgements & decision made by CA

How CA has fulfilled his responsibility in public interst
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AUD300 Summary
Module 12 – Professional Ethics
PART C: CAs IN BUSINESS
Conflict of Interest
NEW:
Responding to
non-compliance
with Laws &
regulations
Preparing &
Reporting of info
CAs in Business Practice
Inducements
Sufficient expertise
Financial Interest
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AUD300 Summary
Module 12 – Professional Ethics
EXAMPLES OF THREATS IN BUSINESS
(READ - NOT STUDY!)

Incentive compensation schemes

Inappropriate personal use of corporate assets
1. SELF-INTEREST

Concern over employment security
THREATS

Financial interests, loans or guarantees

Commercial pressure from outside the employing organisation

Decisions or data reviewed by same CA responsible for making decisions or preparing data

In position to influence financial/ non-financial reporting or business decision and immediate/ close
2. SELF-REVIEW
THREATS
3. FAMILIARITY
THREATS
family member in position to benefit from such

Long association with business contacts – influence business decisions

Acceptance of a gift unless value is clearly insignificant.

Threats of dismissal/ replacement of self or immediate/close family member due to dispute over
4. INTIMIDATION
THREATS
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application of accounting principles or financial reporting

Dominant personality trying to influence decision making
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Module 12 – Professional Ethics
Threats
Safeguards
Financial interest

Internal/external audit procedures


Up-to-date education on ethical matters and legal restrictions
Self or immediate/close family members
regarding insider trading

Policies and procedures for committee of independent manager –
level of remuneration

Disclose relevant interests, plans to trade shares to those charge with
governance

Inducement

Actions to consider:
When an inducement is offered

Inform higher levels immediately
inappropriately to influence professional

Inform third parties of offer – Professional body/employer of
judgement of third party.

Not permitted, whether received by a CA

Consultation with relevant bodies
individual who made offer

Advise immediate or close family members of relevant threats and
or paid by a CA.
safeguards where potentially in positions that might result in offers of
Significance of threat – nature
inducements
POTENTIAL CONFLICTS
Potential Conflicts
Safeguards
Financial interest



Obtaining advice where appropriate from:
Employer’s ethical objectives vs. compliance with
o
Within employing organisation
fundamental principles
o
An independent professional advisor
Exert pressure on employee to:
o
Relevant professional body
o
Act contrary to laws/regulation
o
Act contrary to technical or professional standards
o
Facilitate unethical or illegal earnings management

Existence of formal dispute resolution process with
organisation

Seeking legal advice
strategies
o
Lie to / intentionally mislead auditors or regulator
o
Issue false/misleading statements, i.e. tax, legal, afs
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AUD300 Summary

Preparation and reporting of information
o


Fairly, honestly and in accordance with relevant professional standards
Acting with sufficient expertise
o

Module 12 – Professional Ethics
Undertake significant tasks for which has, or can obtain sufficient specific training or experience
Threats to prof competence& Due care
o
Insufficient time for properly performing or completing duties
o
Incomplete, restricted or otherwise inadequate info to perform duties
o
Insufficient experience, training/education
o
Inadequate resources for proper performance of duties
Safeguards
o
Obtain additional advice/training
o
Ensure adequate time is available to perform duties
o
Obtain assistance from someone with relevant expertise
Responding to non-compliance with Laws & Regulations

CAs must always act in public interest

CAs have responsibility to obtain understanding of legal / regulatory provisions & how non-compliance with L&R should be
addressed, should it exist in a jurisdiction

Objective of responding to non-compliance with L&R:
o
Compliance with fundamental principles: integrity & professional behaviour
o
Alerting management / TCWG to:
o

Enable them to rectify, remediate / mitigate consequences of non-compliance OR

Prevent non-compliance where it has not yet occurred
Take further action as appropriate in public interest
Generally CA not required to comply with this section w.r.t. matters that are clearly inconsequential on client, stakeholders &
general public
This section excludes personal misconduct unrelated to business activities of employing organisation
APPROACH:
1. Obtaining
understanding of matter
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2. Addressing matter
3. Determining wheter to
disclose matter to
appropriate authority
4. Documentation
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Module 12 – Professional Ethics
1. Obtain understanding of matter:

Obtain understanding of non-compliance / suspected non-compliance
o

In course of performing professional activities
Confidential consultation with others in organisation / professional body permitted depending on nature & significance of
matter
2. Addressing matter:

Discuss with immediate supervisor (except if immediate supervisor is involved), then discuss with next higher level
authority in organisation

Should take appropriate steps to:
o
Communicate matter to TCWG
o
Comply with applicable L&R
o
Rectify, remediate / mitigate consequences of non-compliance
o
Prevent non-compliance where it has not yet occurred
o
Reduce risk of re-occurrence

Determine whether disclosure to auditor is necessary to enable auditor to perform audit

Determining whether further action is needed assess:
o

Appropriateness of response by management / TCWG
Further actions:
o
Informing management of parent company
o
Disclose matter to appropriate authority (even if not required to do so by law)
o
Resignation
3. Disclose matter to appropriate authority:

Precluded if doings would be contrary to law/regulation

Deciding whether or not to disclose:
o

Consider actual/potential harm cause by matter to investors, creditors, EEs, general public
Decision also influenced by:
o
Whether there is appropriate authority able to receive & deal with information
o
Whether robust & credible protection exist from civil, criminal / professional liability / retaliation
o
Whether there are threats to physical safety of any person
4. Documentation:
Document:

Matter

Results from discussions with superiors, TCWG & other parties

How above parties have responded to matter

Courses of action considered, judgements & decision made

How CA is satisfied that all his responsibilities have been fulfilled
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AUD300 Summary
AP ACT:
Module 12 – Professional Ethics
IMPROPER CONDUCT
s45 Reportable Irregularity
NB!!
Definition:
Any unlawful act or omission conducted by any person responsible for the management of the entity, which:

Has caused or is likely to cause material financial loss to the entity, or to any partner, shareholder, creditor or investor OR

Is fraudulent or amounts to theft OR

Represents a material breach of any fiduciary duty owed by the person to anybody mentioned above
Actions:

Written report to IRBA (without delay)

Within 3 days notify management of the entity (accompanied with copy of report)

Not later than 30 days
o
Discuss report with management
o
Another report to IRBA

No RI took place

RI has been resolved

RI still taking place

IRBA to take necessary action (disclosure)

Auditor can carry out any investigation to gather info from any source on the RI
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AUD300 Summary
Module 12 – Professional Ethics
Auditing Profession Act (CHAPTER 1 DYNAMIC AUDITING) – read only!
Everything in this summary from this point forward SHOULD ONLY BE READ – do NOT study it!!
AP ACT
READ
Registration of individuals as RAs (s37)
Requirements
Registration refused

Applicant should apply to IRBA.
IRBA must be happy i.t.o. the following:
Previously removed from office of trust because of
misconduct

Completed training contract & passed exams

Convicted of fraud, theft, forgery etc.

Complied with prescribed competency requirements

Unsound mind/unable to manage own affairs

Applicant resident within Republic

Disqualified from registration under sanction

Applicant is a fit and proper person to practise the
(punishment) imposed by APA
profession
Registration of firms as RAs (s38)
Firms that can register:
1.
Partnerships (all partners are individuals and RAs)
2.
Sole proprietors (proprietor must be RA)
3.
Companies (See requirements below)
Requirements for companies to register as RAs:

Incorporated & registered i.t.o Companies Act and have share capital

Memorandum Of Association provides that all directors shall be liable jointly & severally together with company  liable
all debts

Only RAs may be shareholders

Every director must be a shareholder = RAs

Shareholder dies/ceases to qualify -> estate/self may hold shares for 6 months

Members may not appoint other persons than members to act as proxies at meetings
Practice (s41)
Only auditor registered with IRBA and paid fees is permitted
Following ARE NOT prohibited:
to:

Perform Audit

Engaging in public practice (PP)

Present self as RA in PP

Use designation “RA”
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
Salaried person employed using title accountant/internal
auditor

Auditor-General permitted hire any staff that are
unregistered to conduct audits
Page 20 of 21
AUD300 Summary
Module 12 – Professional Ethics
Limitation of Liability (s46)

Auditor will incur a liability i.t.o. opinion expressed or report issued if it is proved that the opinion/report issued
mailiciously/negligent in his conduct.


RA is liable if the 3rd party can prove opinion/report was relied upon and a financial loss was suffered:
o
If RA knew/reasonably knew that it would be relied upon by 3 rd party
o
If RA knew/reasonable expected to know that 3rd party will make decision based on this
o
If RA indicated to 3rd that opinion was correct although RA knew it wasn’t
RA is liable if he does not report the reporting irregularity
Inspections (Practice Reviews) (s47)

IRBA may from time-to-time review the practice of RA but must review RA’s work at least every 3 years

Confidentiality obligation of RA will have to be set aside and will have to present to the reviewer all the required info
Investigation of charge of improper conduct by RAs (s48)

IRBA may order inquiry into circumstances RA failed to perform duties etc.

Impose a punishment deemed appropriate

Examples:
o
Professional fees - RA will not be permitted to share/transfer any audit fees or share profits to anyone not registered
with IRBA
oOo
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