7 actions to consider when facing pressure to act unethically

During the course of your professional life as a member or a registered student, you may face occasions where you are pressured by those around you to cross an ethical line. This may be pressure to ignore, condone, or even participate in illegal activity such as money laundering or fraud.

Often, the reasons for crossing these lines are framed as being down to necessity, expedience, or practicality. Pressure to behave unethically is not always obvious or immediately intimidatory. It can be insidious, and if left unchecked, can become pervasive.

Typical scenarios raised on the CIMA Ethics Helpline include internal fraud, eg, work colleagues fiddling their expenses, amending accounts to cover up bad management decisions or mistakes, and applying pressure to manipulate company accounts to give a false representation of a company's financial health.

If you are asked (or expected) to do something you feel uncomfortable with, it can be particularly difficult to push back if you are working in a high-pressure environment or in a work culture that prioritises results over and above the manner in which the results are achieved. You may have a manager or client who demands that you take a particular course of action, or you may be working as part of a team where unethical work practices are normalised. You may want to raise concerns but are apprehensive about the way in which these will be received.

You may have your own personal commitments, family, and other considerations that make pushing back a risk. You may not be comfortable with confrontation, or the pressure may be coming from someone more senior than you. Alternatively, it may be more intangible: It may be the culture of the organisation that pushes you to engage in unethical behaviour without anyone expressly telling you to do so.

Here are tips to help if you ever find yourself being pressured into unethical conduct:

Know your business's culture

Often, people consider how best to respond to pressure to behave unethically after the situation has occurred, but by that point you are already in the thick of it. It can be useful to prepare yourself before such dilemmas occur.

Before taking a job or engagement, it is helpful to have an understanding of your employer's or client's business culture and the behaviour that is expected of employees — and build that understanding once you are in a position. Be sure to do your research before taking a position and ask questions throughout the interview process.

Understand your professional obligations

Be confident you understand your obligations under your professional body's code of ethics so that you can apply them when pushing back. It will then be easier to resist undue pressure and maintain these standards in times of stress.

Section 280 of Part 2 of the CIMA Code of Ethics addresses pressure to breach the rules or fundamental principles.

The Code recognises that "pressure exerted on, or by, a member might create an intimidation or other threat to compliance with one or more of the fundamental principles or the rules". In particular, Section 280.3 (a) is clear that a member shall not allow "pressure from others to result in a breach of compliance with the rules". Advisory clauses in the Code give examples of the types of pressure members might face and where they might come from, and provide suggestions for how a member can approach these circumstances.

When pushing back, as a CIMA member it may be useful to highlight the professional obligations that exist to reinforce your position, explaining the consequences associated with breaching these obligations. Drawing attention to CIMA's indicative sanctions guidance can be a further way to push back against pressure to act unethically if pressured to do so by another CIMA member.

Put the facts into context

It is important to understand the facts in context before you diagnose the problem. For example, have you spotted a practice that has remained unchecked for some time, or are you being asked to do something unusual for which there is no precedent? Are others being asked to look the other way, or is it just you? Is the pressure coming from senior managers or your own colleagues? Understanding the motivation for the pressure will be an important part of your solution.

The Code requires you to be objective, and objectivity can be a useful tool in keeping emotion out of the situation when dealing with pressure. Management will be more receptive to an issue if you describe the problem based on the facts, the risks to the business, and propose a solution.

Raise the issue with your line manager

When you are ready to take action, the best approach is to raise the issue with your line manager. Problems arise when your manager is unreceptive or indeed if they are the perpetrator of the unethical practice. Talking to the right people can help you think through a dilemma. Someone at a similar level in the organisation may have gone through something similar and so can share useful insights. There may be someone else in a senior position at your organisation who is able to support your position and intercede on your behalf. You may have a mentor or career coach who can provide useful guidance. It may even be a colleague whom you trust and who just listens.

You may also wish to consider obtaining external guidance or advice. CIMA's ethics helpline and inbox can direct you to useful resources and help you decide on a strategy that suits your particular situation.

Point out potential reputational damage

A useful tactic for pushing back when pressured to act unethically can be to point out the potential reputational damage to a business. You could ask your senior decision-makers, "How would this look if it ended up on the front page of tomorrow's newspaper or went viral on social media?"

For companies with a public profile, there may well be a public interest in your work, and unethical or illegal activity could lead to a very public scandal with far-reaching consequences.

Reminding others of reputational risks and associated fallout as a means of highlighting the consequences of unethical behaviour is an important part of pushing back.

Consider further action

Identifying, evaluating, and addressing threats are covered in Section 120 of the Code.

Sometimes it is not possible to reduce a threat, particularly if the pressure continues. In these circumstances it may be necessary to disassociate. You may be able to have your name removed from a misleading report (see Subsection 111 – Integrity – of the Code), or you may comply with a management decision you are uncomfortable with if you can secure a commitment to a review of business practice to prevent it from happening again. Unfortunately, the ultimate disassociation is resignation, and you may feel that this is your only option if you consider your position to be untenable.

If you are unable to solve a serious threat, you may feel that you have no choice but to report it more widely. It may be appropriate to inform all the directors of a business of a situation where you are being pressured by one individual. You may also consider Section 200.11 of the Code, "Communicating With Those Charged With Governance". Ultimately, you may feel that you have no alternative but to become a whistle-blower. Larger employers may have a confidential "speak-up" helpline, and the Protect advice line offers expert and confidential advice on how best to raise your concern and your protection as a whistle-blower.

Always keep records

How you proceed will ultimately be determined by many factors, but you should always be sure to keep contemporaneous records to document the actions you take. These will be invaluable resources to anyone providing you with support and/or any appropriate third parties that may end up intervening. CIMA recommends that you document:

• The facts.

• Courses of action considered.

• The advice you gave.

Make sure you follow up any conversations you have with an email confirming the advice you gave. Keeping accurate and up-to-date records of your steps will save you a lot of trouble moving forward. You may never use them — however, it's better to have them should your decisions be challenged.

— Xose Lumor is the manager, Advocacy & Professional Ethics–Management Accounting at the Association of International Certified Professional Accountants, representing AICPA & CIMA, and is based in the UK. To comment on this article or to suggest an idea for another article, contact Oliver Rowe at Oliver.Rowe@aicpa-cima.com.