Ethics in action: 'Just make something up!'

The modern workplace can be an ethical minefield. This monthly column helps you tackle the thorny, but very real, challenges that management accountants face in the workplace.

Written by the CIMA professional standards team and based on realistic situations, the following is a practical guide to using the CIMA Code of Ethics to guide good decision-making.

The scenario

You work for a consulting company. You have been asked to take the lead on producing the organisation’s annual integrated report, and your name will appear on the report as the lead author.

In addition to the financial data, you have been asked to collate information from a number of departments on the broader performance of the organisation. Investors, customers, and employees are all expecting more from business when it comes to acting in the interests of wider society, so you ask the COO to provide information on environmental and social indicators. He emails back telling you to “just make something up — say we reduced plastic usage in the offices and donated some money to save the bees or whatever”.

The COO is much more senior than you and is known to be a tricky person to work with. You worry that if you push back, he will be angry and you might be passed over for a promotion you are hoping to achieve next year.

What should you do?

Ethical issues and guidance

In this scenario, a senior colleague is asking you to falsify information in the organisation’s annual report.

The CIMA Code of Ethics makes it clear that you must not produce misleading reports. Under the fundamental principle of integrity, the Code states: “A professional accountant shall not knowingly be associated with reports, returns, communications or other information where the accountant believes that the information:

(a) Contains a materially false or misleading statement;

(b) Contains statements or information provided recklessly; or

(c) Omits or obscures required information where such omission or obscurity would be misleading.”

Whilst at first glance this may not seem as serious as falsifying financial reports, you should consider the possible implications of misleading stakeholders by misrepresenting the company’s environmental performance.

Increasingly, stakeholders are holding organisations to account when it comes to environmental data. Clients may have criteria for selecting consultancy firms, such as only working with organisations which have made a commitment to achieving net-zero. An integrated report is likely to be a key piece of evidence potential partners use to verify performance.

If you were to include false or misleading information in the integrated report, this could have serious negative impacts down the line should a stakeholder find out about it. There could potentially be legal ramifications. It could also have a serious impact upon the reputation of your organisation, were it discovered that the information provided is inaccurate.

You may wish to consider whether anyone else in the organisation could provide you with truthful information you could include. Even if there isn’t a sustainability team, other employees may be involved in relevant activities. For example, there might be an employee environmental group that has organised initiatives in specific offices focused on reducing plastic use, or employees may have used volunteering days to support local causes.

If nothing is happening currently, try to find out whether there are plans for the future which you could mention — for example, has the organisation or any specific department committed to reducing carbon emissions?

You could look at last year’s report to see what has been said previously. If the company is adopting integrated reporting for the first time, there may be nothing wrong with simply including a section that describes the company’s intention to begin sustainability practices and be in a position to report on these next year. This is something positive to give to stakeholders right now and sets the scene for development internally.

As a professional management accountant, you may be in a position to influence the future direction of the organisation by encouraging the COO and CEO to do more on sustainability, highlighting the demand from a range of stakeholders when making the business case. You could ask your manager to give you the responsibility of developing an internal sustainability strategy that is supported by suitable processes, or work with colleagues to form an employee-led sustainability group.

You may wish to discuss your concerns with your manager, who might be able to provide support in deciding the best approach to take, especially given the COO’s potentially volatile personality. Whatever happens, your name must not appear on any report which you know or suspect includes false or misleading information.




Bryony Clear Hill is the associate manager–Ethics Awareness for CIMA and is based in the UK. To comment on this article or to suggest an idea for another article, contact Drew Adamek, an FM magazine senior editor, at