At the ICA, our focus is to support our members and students to be the best they can be. Ethical excellence is integral to this approach.
By studying with or becoming a Professional Member of the ICA, you recognise the importance of working to the highest standards of best practice in compliance, anti money laundering and financial crime prevention and, by doing so, achieving benefits above and beyond those delivered by meeting regulatory requirements.
This Code applies to all ICA members and is intended as guidance to help in your everyday work and in situations where you are faced with difficult decisions.
ICA views ethical behaviour as an integral part of demonstrating and maintaining professionalism. We expect all of our members to embrace the spirit of the code with the understanding that should a clear infringement of the Code’s principles come to the attention of the Association, it would be just cause to trigger a further investigation. If the outcome of such an investigation was confirmation that a member was in breach of the code, a disciplinary hearing would follow, giving the member the right to defend their actions. One possible outcome of such a disciplinary hearing would be withdrawal of membership, which the Association reserves the right to make public.
Members should make every effort to apply the Code.
The components of the Code should be considered in combination – although they are divided into subsections of Judgement, Behaviour and Development for ease of recall. They embody important principles of compliance and regulation that are upheld internationally.
ICA members are expected to uphold the highest levels of integrity and professionalism. This will be demonstrated by a series of behaviours that include (but are not limited to) the following:
Compliance professionals must…
1. … uncover and consider the ‘spirit’ and intent of regulation and consider its implications from the perspective of all key stakeholders. They must avoid any over-simplification that diminishes the value and importance of compliance.
2. … protect and ensure their independence and alert senior management or regulators should this be compromised. They must understand that the integrity and effectiveness of compliance is founded on independence of thought and judgment.
3. …take difficult decisions. This requires exercising mature judgment in balancing competing priorities and conflicts of interest, interpreting ‘grey’ areas, making fine judgements and decisions and then acting with the appropriate degree of sensitivity.
4. …be pro-active in building a positive culture in their firm that understands, respects and is committed to regulatory objectives, values and outcomes.
5. … hold a unique and significant position with accountability to the firm and the relevant regulatory authorities and must be clear and transparent about their responsibilities and the limitations of their scope.
6. … be able to raise uncomfortable issues and ask challenging questions. They should contribute to enabling constructive challenge at all levels in the organisation.
7. … remain committed to open, clear, accurate, timely and accessible reporting internally and to regulators. Transparency is unconditional.
8. … aim for open relationships with colleagues, offering high-quality advice and guidance, yet understand where ownership of risk lies.
9. … perform a role that includes: regular briefings, inductions, training, horizon scanning, and compliance planning. As such they need to ensure that they have a direct voice to the board of directors (or its equivalent). They have a role to assist in the education and development of colleagues.
10. … develop their own competence through appropriate qualifications and continuous professional development and avoid exceeding the limitations of their competence.
ICA will continue to up-date and develop this Code so any examples of how the Code has been useful or how it could be improved are welcomed. Please email us at email@example.com with any feedback.
The ICA code of conduct video
Consequences of non-compliance
Members must understand that should a clear infringement of this code or the principles it contains come to the attention of the Association, it would be just cause to trigger a further investigation.
If the outcome of such an investigation confirmed that a member was in breach of the code it would lead to a disciplinary hearing that gave the Member the right to defend their actions.
One possible outcome of such a disciplinary hearing would be a withdrawal of Membership, which the association reserve the right to make public.