| TRANSPARENCY REPORT
49
ETHICS: INTEGRITY, INDEPENDENCE AND OBJECTIVITY
instance of apparent non-compliance with the
RES, any necessary actions are agreed with the
individual(s) concerned and the AMT. The details
are then reported to the Ethics Partner, to
consider whether any further action is required.
Compliance with policies and procedures is
monitored including:
● recording the length of service of all
audit partners and senior members of
staff involved in an audit;
● review of any gifts and hospitality
received, with particular regard to
PIE engagements;
● keeping outstanding fees under
review; and
● monitoring of Non-Audit Service fees
charged to PIEs.
All staff and partners have to complete annual
declarations and declare any change in such
relationships throughout the year. Each year,
a summary report in relation to the 'fit and
proper' and the independence declarations
that all principals and staff need to make is
provided to the Ethics Partner, and reports
are made biannually to the Financial Reporting
Council (FRC) of instances of breaches of
ethical norms, with rectification following
soon afterwards through root cause analysis,
conclusions on learning points to deter
repetition being made, and any other action
deemed necessary being taken.
Independence is further bolstered by internal
reviews of independence practices, the
publication of a collation of current ethical
issues, and the carrying out of 'thematic
focuses' on key issues.