Embedding ethical values in the corporate culture: ZAMBIA

Transcription

1 Embedding ethical values in the corporate culture: ZAMBIA This paper summarises the discussions from a roundtable held in August at the 2013 Annual Business Conference in Livingstone. A group of professional accountants discussed both ethical challenges that can be faced in corporate life as well as giving recommendations on how best to safeguard against risk and how to strengthen a culture of integrity. Special edition - February 2014

2 About CIMA The Chartered Institute of Management Accountants, founded in 1919, is the world s leading and largest professional body of Management Accountants, with over 203,000 members and students operating in 173 countries, working at the heart of business. CIMA members and students work in industry, commerce, the public sector and not-for-profit organisations. CIMA works closely with employers and sponsors leading-edge research, constantly updating its qualification, professional experience requirements and continuing professional development to ensure it remains the employers choice when recruiting financially-trained business leaders. Professionalism and ethics are at the core of CIMA s activities with every member and student bound by robust standards so that integrity, expertise and vision are brought together. CIMA has formed a joint venture with the American Institute of Certified Public Accountants (AICPA) to establish the Chartered Global Management Accountant (CGMA) designation. CGMA is the global quality standard that further elevates the profession of management accounting. About Institute of Directors Zambia The Institute of Directors of Zambia (IoDZ) was launched on 7th April It is a leadership forum, committed to the development of members through education, and training; and exchange of information in order to enhance the quality of leadership and Corporate Governance in the private and public sectors in Zambia. IoDZ provides services to members that will enhance and facilitate their professional development for the ultimate benefit of the community at large. The services offered range from forums, workshops, networking evenings, in house training, information and advisory services, ethics awareness and management training, and other corporate services. Acknowledgement and disclaimer With thanks to the organisations that contributed to the discussions facilitated by Tanya Barman, Head of Ethics, CIMA. These representatives drew on their experiences of working with companies across a range of sectors in Zambia and internationally. Contributors included: AB Bank, Real Time, Zambia Development Agency, Pax Consultants, Stanbic Bank and African Life Assurance. The summaries of these discussions represent the personal views of participants and are not the views of companies or countries as a whole. The discussions are intended to increase the reader s knowledge of current ethical issues faced in business locally and do not provide a quantitative evaluation of opinion. Neither the organisations involved nor the individuals representing them are responsible for the contents of this paper.

3 Contents Introduction 1 Zambian overview and context 2 Discussion summaries: 3 1. Who is responsible for ethical conduct and how is it communicated and supported? 3 2. What can be done to combat corrupt business practices and how can the external environment be influenced? 4 3. What ethical information is useful and what is the role of finance? 5 Conclusion 6 References and other resources 7

4 Introduction To coincide with the Zambian Annual Business Conference in August 2013, a roundtable was held in Livingstone which brought together representatives from various organisations, including SMEs, larger Zambian owned companies and multinationals across different sectors, to discuss the issues of embedding ethical values into the corporate culture of an organisation. CGMA and CIMA global research has shown that, despite codes of ethics and related initiatives which set an increasingly ethical tone, there has been a reported rise in pressure to compromise standards of ethical business conduct. Findings from CIMA s recent report Acting Under Pressure 1 affirmed that a transparent operating culture, support from management and compliance with both local and international regulations and norms, are necessary to establish an ethical environment. With the potential for being caught out for unethical business practices and the resultant reputational and operational costs, embedding ethical values into operating cultures should be a strategic focus. Furthermore, an economy backed by effective regulation and accountability offers a more level playing field and can attract investment and entrepreneurship policy areas that the Zambian government is keen to pursue. Through the roundtable we wanted to understand what companies in Zambia are doing to safeguard themselves against bad practices, identify risks and work towards an open and fair corporate culture by embedding ethical values. Growing research shows that ethical practice makes a difference in supporting long term success of companies, particularly in relation to risk. Public interest is increasingly important, as events played out globally in the last few years have shown, and this is further backed by the rise of influence from wider society via social media and online media channels. This is also the case in Zambia, with a growing interest in transparency and accountability on the part of civil society and business groups. These are key issues for companies of all sizes who recognise that they must take very seriously any risk to their reputation in order to prevent problems turning into catastrophes. Risk assessment needs to include areas such as ethos, culture and behaviours within an organisation 2. The roundtable focused on three aspects of corporate activity in relation to ethical practice. Summaries of these discussions, as well as recommendations, are compiled in this discussion paper to help other companies both reflect on their practices and consider how best they can reinforce integrity in their business. As more companies embed good practice, the wider business environment should improve, and in turn civil society and the wider economy should also benefit. 1 Acting under pressure how management accountants manage ethical issues, CIMA, Roads to Ruin: A study of major risk events: their origins, impact and implications, a report by Cass Business School on behalf of AIRMIC, sponsored by Crawford and Lockton, Embedding ethical values in the corporate culture: Zambia

5 Zambian overview and context In CIMA s global survey 3 on responsible business and how accountants respond to ethical challenges, 84% of respondents from Zambia stated that their organisations had a code of ethics, compared with a global average of 80%. However, Zambian respondents were more likely than respondents in any other country to be under pressure from colleagues to compromise these standards, 60% against a global average of 36%. There was a lower level of provision of anti-corruption guidelines, 49% against a global average of 58%. Less than a quarter in Zambia (22%) had access to a hotline for reporting conduct that violates the organisation s standards of ethics against nearly half (48%) globally. This highlights risks in the business environment. Ensuring that there is a culture of support for ethical behaviour, as well as clear guidelines and reporting routes, is an important aspect of responsible business. It did appear that in Zambia when violations come to light, employees are most likely to be disciplined, with 84% agreeing the highest of any market. Zambia s economy has greatly developed in recent years and policies for attracting foreign direct investment and strengthened regulatory frameworks have helped encourage this. Zambia is also making progress in the fight against corruption, although it still ranks lower than 11 other countries in the African Continent. Its rating on the Transparency International Index has risen from 3.2 to 3.7. But given that 10 is clean and 0 is bad, there is still a lot of work to be done and no room for complacency in continuing to focus on structural reforms and to increase legal frameworks, efficiency and transparency. It is acknowledged that widespread corruption acts as a barrier to entrepreneurial incentives in growing markets. Economic growth and efforts to diversify the economy and support local enterprise have resulted in a larger middle class with higher consumer power. As a direct consequence Zambia is now less dependent on overseas aid. The World Bank Economic Brief of 2012 recognises the strong gains in economic performance, but also references the need to address issues of poverty, as well as maternal mortality and secondary education 4. The long term investment prospects of an economy, both for internal and inward investment, are connected not only to regulatory and institutional stability but also the overall spread of prosperity, secure livelihood, education and child welfare. A spotlight has recently been thrown on the tax affairs of some multinationals operating in Zambia. This was highlighted in the G8 meetings in Northern Ireland in June 2013, with the Africa Progress Panel 5 citing Zambia in its findings. There is a push towards regulating and monitoring foreign exchange flows in a bid to curb tax avoidance and to monitor balance of payments in a more transparent and equitable manner in order to bring benefits to citizens more widely. Addressing the needs of wider society clearly matters to CIMA members and students. Respondents from Zambia agreed, at 100%, that business has a moral obligation to help address global issues such as climate change and poverty, against the global average of 82%. It was also respondents from Zambia who most highly agreed, at 97%, that their organisations would benefit from collecting ethical management information. This includes evaluation of standards, codes and policies, and more specific measures such as monitoring the occurrence of breaches of a company s policies or code, number of employees attending ethics training, risk analysis or supplier due diligence. As most of the respondents to the survey in Zambia were those studying CIMA, the results may reflect a tendency of students to have a stronger interest in ethical behaviour and sustainability than members. With the rising trend towards integrated reporting and increasing value attributed to information derived from the non-financials, this bodes well. There is great promise therefore that, given the right will, by ensuring there is an ethical culture to reflect the codes in place, and stronger legal and regulatory frameworks, Zambia can support and grow responsible business for sustainable long term success. 3 Acting Under Pressure how management accountants manage ethical issues, CIMA, Embedding ethical values in the corporate culture: Zambia 2

6 Discussion summaries 1. Who is responsible for ethical conduct and how is it communicated and supported? Although the majority of organisations recognised that the board and senior management have overall responsibility, a number of companies do put an emphasis on raising awareness among all staff. It was more likely to be the largest organisations, or those with international presence, that put shared responsibility into practice. This was most apparent in regard to staff training, awareness raising and engagement. Although all organsations had a code of ethics, or relevant policies related to ethical conduct, not all of them were sure that staff would be aware of such guidelines or their responsibilities. Best practice examples included having an ethical champion, mandated by the leadership, who was able to promote ethical behaviour and formally raise ethical issues and concerns on behalf of the staff. Ethical champions included a nominated member of staff, or a member of a management committee. An ethics programme of training and communication which continues to remind staff of their duties and obligations is important in order to establish an ethical culture. The example was cited of a professional services company where it was mandatory for all staff to complete e-tests on ethics which have to be passed and which are repeated throughout the year. Penalties for incomplete tests ensure that they are not seen as optional. This was backed by wider awareness raising activities, such as ethical messages appearing on computer screens. Another regional financial services organisation routinely tested their employees to assess their level of understanding and awareness of their code. Reflecting the CIMA research (which indicates that only a small minority of companies have hotlines for reporting issues), only one of the organisations, a global firm, had a well advertised speak-up line for raising issues against a clear protocol. This has been well used and examples were given of issues being internally resolved on this basis. Being alerted to and then resolving issues quickly within the business, is far preferable to letting an issue grow and relying on external whistle blowing. There may be issues where supervisors or peers could be part of the problem, therefore anonymous reporting lines or other routes of confidential escalation should be available. In the Zambian context there are difficulties in being seen to report on a colleague, particularly when work and civic life are closely connected. Having in place a mechanism where concerns can be reported for others to take forward and fairly investigate may address this. The importance of engagement with both human resources (HR) and finance departments was highlighted. This should encourage alignment of policies but also to raise ethical awareness among the wider staff, including identifying red flags 6 and how to report them. Such information should be shared at induction and should be ongoing. Organisations with parent companies generally have their codes of ethics driven down, as well as related performance management systems being reviewed up the line to the parent company, sometimes in another geography. The importance of encouraging local engagement, input, and ownership was emphasised to ensure such values were adopted. One local financial services company raised awareness of ethical conduct not only among their staff but also between staff and customers. This has been used to draw attention to discrepancies by branch workers in the community. Internally the company actively encourages open discussion of issues that arise and gives its staff responsibility to bring concerns, with appropriate evidence, to their supervisors who will in turn raise it with the relevant committee to resolve. One of the organisations had only recently introduced a code, reflecting the board s desire to strengthen corporate governance. As yet no staff awareness or training had taken place and this was to be the next phase as directed by the relevant committee. Having a code with no mechanism to disseminate or influence wider management cannot improve a culture. Support should be drawn from HR and finance in actioning this. This was recognised as a common position for companies in Zambia, particularly smaller companies. It reflected awareness and a will to strengthen corporate governance by introducing a code but it also highlighted the need to plan implementation if ethical values are to be embedded across the organisation. 6 Red flag is an expression commonly used to identify a situation or a fact which requires further information to assess in effect a warning signal. Understanding and addressing a potential issue early on helps mitigate further problems. 3 Embedding ethical values in the corporate culture: Zambia

7 Recommendations The board and leadership team need to take overall responsibility for putting a code in place and then communicating it throughout the organisation. They have to model the ideal behaviours they wish their staff to follow. Testing staff understanding of the code, and give them regular opportunities for raising issues, ensures the code is followed and used. Help reinforce ethical values and the use of the code by appointing ethics champions to report back to the board. Put channels in place for staff to report issues and concerns via a hotline, with a clear protocol for escalation. Anonymous reporting lines may be valuable. Engage both finance and HR teams in creating relevant policies, communicating the code and encouraging discussion. Respond to issues raised, so that staff have confidence that they can speak up, and appropriately discipline those who breach the organisation s stated standards. 2. What can be done to combat corrupt business practices and how can the external environment be influenced? It is important to raise awareness and put in place structures and support to guide staff in their actions and encourage them to report concerns. Staff need to trust their organisation and have confidence to do the right thing. This can start by ensuring that those who are hired into an organisation reflect the values and ethical standards of the employer 7. In the banking sector, for example, the Banker s Association provides a reference check for new employees. In regard to accountants generally, checks can be made with their Institute. In the public sector employees may need to be cleared by the Zambia Intelligence Agency. It was widely agreed that the character of those brought into employment is a key determinant of ethical behaviour, although this is not always easy to test. There could be pressures to hire individuals who have transgressed ethical standards previously, particularly if they boast influential or powerful connections. There is always a risk that it might not be known if an individual has engaged in unethical behaviour, fraud for example, as some firms may not report or take action on such issues. The risks result from fear of damaging their reputation, or from the difficulty of raising a complaint. Key barriers are related to weaknesses and poor resourcing in the judicial and legal systems. The length of time it can take for cases to go through can create costs for the organisation and therefore there is a need for fast tracking of certain cases, both to assist speedy resolution in a more cost-effective way, and to send clear messages by taking action against those found to act outside the law. Additional issues raised included the impact on the culture of an organisation when it is subject to a merger or acquisition. This can create a number of risks. Internal control by those most familiar with the operations and staff of the organistion is recognised as important, and outsourcing such activity or having it overseen by a distant department can undermine effectiveness. However, there should be a mechanism for external audit and assurance. Personal values have a big role to play, emphasising the importance of leadership style and ongoing education amongst all the staff. At present there is no attention to ethics in the formal curriculum at schools, so an individual s behaviour is driven primarily by the values learned in their personal life. Clarifying what is unethical can be just as important as highlighting the ethical route and it is important never to make assumptions about what people may consider is the right thing to do. The example was given of a high use of company phones for private use. Once the system was digitised, each individual s calls were tracked and their non-work calls charged. Behaviour changed rapidly. In addition to education and discussion of the importance of acting ethically, enforcement against poor practice is a powerful deterrent. To know the consequences of doing wrong can make a big difference in behaviour. Procurement was raised as a high risk area, and many participating organisations acknowledged that issues often arose from purchasing and supply. Focusing attention on best practice and professional standards in these departments should be seen as a priority in Zambia and action should be taken against those who contravene standards in place. Related to this is the need to ensure due diligence not only of suppliers but also of customers. Bad practices by those you are associated with can affect your organisation, not only in negatively influencing behaviours, but ultimately in reputation, and strengthening standards in the supply chain should be a priority. 7 See IBE s guidance on Ethical Due Diligence in Recruitment Embedding ethical values in the corporate culture: Zambia 4

8 Currently it is not usual for sectors to come together and discuss shared challenges and solutions. This is a practice that the professional associations could encourage to enable their members to learn from best practice, as well as to influence change at a regulatory and government level. This would help people to learn where the high risks are and how to deal with them. Change is possible. The example was given of how the reporting of petty bribes to traffic police via a recently introduced government hotline can contribute to changing practices in a short time. This is similar to initiatives set up by civil society groups in other countries for example the I paid a bribe website 8 in India which is part of a wider citizen attempt to fight corruption and create a fairer society. Government has made some strides in addressing the issue for example by establishing the Anti-Corruption Commission. Transparency International ranking of Zambia 9 has shown improvements in recent years. However, the ranking is still low and there is high risk of corrupt practices particularly in the public sector. Implementation of the Commission s objectives should be encouraged and this will need to be supported by strengthening the judicial system. Recommendations Consider carefully the criteria used when hiring staff, test for ethical understanding and application as well as making relevant checks on their past performance. Clearly stipulate in writing and remind staff verbally of policies and the do s and don ts. Remove assumptions and explicitly agree standards of behaviour; this will strengthen the culture and make it easier to take action against contraventions. When acquiring or merging with another organisation consider the cultural fit and how ethical practices may be affected. Ensure you retain strong internal controls with support from HR and finance. Seek to work with other companies in a similar sector to share good practices and address weaknesses at both organsational and wider policy level. Exercise due diligence on both suppliers and key customers. Actively engage and work with organisations who have similar values and practices. Encourage engagement and collaboration between the professional institutes, regulatory authorities and the law to improve standards for the wider business community. 3. What ethical information is useful and what is the role of finance? It is important to document the activities that are taking place in an organisation to embed ethical behaviour and to emphasise the organisation s values. Therefore it is advised to track staff that have undergone training and assess their understanding of their commitments. Due diligence should be exercised with employees, suppliers, customers and partners who will be associated with the organisation, and the outcomes tracked. Risk and compliance departments can assist in collecting and acting upon such information but will need the support of other business units such as HR, procurement and sales. Contracts should be revisited to ensure that they align with a company s values and operating standards. If a hotline or similar reporting mechanism is in place, any issues arising should be discussed at leadership level and a response to concerns should be documented to show how issues are resolved and dealt with. Whistleblowing legislation has recently been introduced in Zambia and companies should seek advice and support from the relevant authorities and advisors in this regard. Internal controls should be regularly reviewed, and improved, as necessary with a focus on reflecting what is important to the business and addressing any red flags through clear protocol. Employee engagement surveys can be one way to assess if there are any management problems. The finance team have a key role to play in being sensitive to any anomalies in transactions as well as ensuring that regulatory standards are adhered to. Effective systems and controls for the day to day business activities can offer valuable management information to be used for corporate governance Transparency International: 5 Embedding ethical values in the corporate culture: Zambia

9 The board should have insight into the behaviours of those at the front line of the business activity, and be aware of the potential pressures they face. They should seek guidance in strengthening their mandate and role 10. The Board should be able to gauge how open the culture of the business is, how comfortable staff feel about speaking up and how confident they are of not facing retribution. Economic and social pressures mean that many employees have a high fear of losing their work, with very damaging consequences for their family and future career. Integrated reporting 11 is gaining interest, and the ability of the finance team to monitor and track non-financial information, such as the value of people, resources and wider society, is increasingly seen as essential to reporting on the full health of an organisation, as well as to identifying opportunities and risks. Just reviewing the balance sheet in terms of profit and loss on a quarterly basis is no longer enough. Chartered and certified accountants are obliged to uphold their professional code. They should reflect on their commitment and advise the organisation of any risks in the operating structure of the business. They are often the professionals that are listened to within the organisation in relation to establishing business models or recommending cost cuts. They have an influential role in persuading the organisation to adopt safeguards and to mitigate risks. These include those recommended in the CIMA Code of Ethics which is based on the IFAC Code of Ethics 12. Information should be carefully considered in relation to its materiality. An organisation is at risk if its marketing messages talk about corporate responsibility, charity giving, or supporting local projects, when other business conduct, such as bribery or poor health and safety, threaten both the workforce and civil society. There is a need to identify the value drivers of an ethical company how it treats its staff, suppliers, customers and wider community, and assess how this is actioned. The United Nations Global Compact, for example, highlights ten business principles in the areas of human rights, labour, the environment and anti-corruption 13. Companies that perform highly against such criteria could become champions for good practice and bodies such as the Institute of Directors could recognise them through annual awards. The professional institutions, business associations and relevant government bodies could work together to showcase best practice and business success through operating ethically. Recommendations Collect, monitor and analyse information related to the organisation s ethical standards and compromises of such standards. Regularly audit information to ensure that it has credibility and usefulness. Consider which key areas are material to the business and focus on them. Identify risks in current systems and structures and put in safeguards which are recommended as best practice by national and international regulators and advisors. Celebrate and profile companies that perform well and share their practice. Finance has a key role in identifying risk and implementing safeguards and should be advising the board as necessary to take action. Seek advice and support from professional bodies and regulators as to guidelines and systems to put in place to suit your business. Conclusion There is a trend in Zambia to focus on corporate ethics, although experience shows that practice is very variable. With growing emphasis on corporate governance and greater interest from not only employees but the wider public, there is potential for such practices to spread. However, this will take commitment from leading organisations as well as the necessary support from government and regulatory authorities. Companies, professional institutes and trade bodies have much to offer and by working together, by sharing good practice and highlighting successful case studies, they can be the champions for change in corporate culture. 10 A number of toolkits on strengthening the Board s mandate and communication are available from Tomorrow s Company See to of the CIMA Code of Ethics 13 UNGC Ten Principles: Embedding ethical values in the corporate culture: Zambia 6

10 References and resources Acting under pressure how management accountants manage ethical issues, CIMA, 2012 Roads to Ruin: A study of major risk events: their origins, impact and implications, A report by Cass Business School on behalf of AIRMIC, sponsored by Crawford and Lockton, 2011 Ethical Due Diligence in Recruitment, IBE Briefing, Issue 17, November 2010, I Paid a Bribe, India, Corruption Perceptions Index, Transparency International, 2012, The case for the Board Mandate, Tomorrow s Company Good Governance Forum, 2010 The Board Mandate Toolkit, Tomorrow s Company Good Governance Forum, 2010 Board Conversation Toolkit, Tomorrow s Company Good Governance Forum, 2010, good-governance-forum CIMA Code of Ethics, 2010 (based on the IFAC Code), Collective Action Information and resources Siemens Integrity Initiative International Integrated Reporting Council, CIMA has a range of resources on ethics and responsible business at including an ethical decision making tool based on scenarios that might arise that conflict with finance professional s Code of Ethics: For CGMA ethics resources and reports see: 7 Embedding ethical values in the corporate culture: Zambia

11 Examples of ethics, sustainability and responsible business initiatives International Integrated Reporting Council: Launched in August 2010, the objective of the IIRC, a cross-sectoral initiative of the Prince of Wales Accounting for Sustainability Project (A4S) and the Global Reporting Initiative is to create a globally accepted framework for accounting for sustainability that brings together financial, environmental, social and governance information in a clear, concise, consistent and comparable format. The intention is to help with the development of more comprehensive and comprehensible information about an organisation s total performance, prospective as well as retrospective, to meet the needs of the emerging, more sustainable, global economic model. The council and working groups involve representatives from the corporate, accounting, securities, regulatory, non governmental organisation, and standard-setting sectors. See: Organisation for Economic Co-operation and Development Guidelines for Multinational Enterprises: First drafted in 1976, these are recommendations addressed by governments to multinational enterprises operating in or from adhering countries. They provide voluntary principles and standards for responsible business conduct in areas such as employment and industrial relations, human rights, environment, information disclosure, combating bribery, consumer interests, science and technology, competition, and taxation. The guidelines are the most comprehensive instrument in existence today for corporate responsibility multilaterally agreed by governments. See: United Nations Principles for Responsible Investment (PRI): With the growing view among investment professionals that environmental, social and corporate governance (ESG) issues affect the performance of investment portfolios, the PRI provides a framework for investors to assist in these considerations. They are not prescriptive, but instead provide a menu of possible actions for incorporating ESG issues into mainstream investment decision making and ownership practices. The principles came into being in 2006 on the back of a UN initiative and in early 2010 there were 785 signatories. Applying the principles should not only lead to better long-term financial returns but also a closer alignment between the objectives of institutional investors and those of society at large. See: United Nations Global Compact: The UN Global Compact is a strategic policy initiative for businesses that are committed to aligning their operations and strategies with ten universally accepted principles, in the areas of human rights, labour, environment and anti-corruption. By doing so, business, as a primary agent driving globalisation, can help ensure that markets, commerce, technology and finance advance in ways that benefit economies and societies everywhere. In 2010 the UNGC stands as the largest corporate citizenship and sustainability initiative in the world with more than 7,700 corporate participants and stakeholders from more than 130 countries. See: Dow Jones Sustainability Index: Launched in 1999, the Dow Jones Sustainability Indexes are the first global indexes tracking the financial performance of the leading sustainability driven companies worldwide. See: Global Reporting Initiative (GRI): is a network based organisation that has pioneered the development of the world s most widely used sustainability reporting framework and is committed to its continuous improvement and application worldwide. Sustainability reports based on the GRI framework can be used to benchmark organisational performance with respect to laws, norms, codes, performance standards and voluntary initiatives; demonstrate organisational commitment to sustainable development; and compare organisational performance over time. See: Transparency International (TI): Working through more than 100 national chapters worldwide and an international secretariat in Berlin, Transparency International works with partners in government, business and civil society to put effective measures in place to tackle corruption. Annually TI produces The Corruption Perceptions Index. It measures the perceived levels of public sector corruption in countries worldwide. Based on expert opinion, countries are scored from 0 (highly corrupt) to 100 (very clean). Some countries score well, but no country scores a perfect 100. Two-thirds of the 176 countries ranked in the 2012 index score below 50, showing that public institutions need to be more transparent, and powerful officials more accountable. See: Embedding ethical values in the corporate culture: Zambia 8

12 2014, Chartered Institute of Management Accountants. All rights reserved. The information and any opinions expressed in this material do not represent official pronouncements of or on behalf of CIMA. This material is offered with the understanding that it does not constitute legal, accounting, or other professional services or advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The information contained herein is provided to assist the reader in developing a general understanding of the topics discussed but no attempt has been made to cover the subjects or issues exhaustively. While every attempt to verify the timeliness and accuracy of the information herein as of the date of issuance has been made, no guarantee is or can be given regarding the applicability of the information found within to any given set of facts and circumstances. ISBN: Chartered Institute of Management Accountants CIMA corporate centre 26 Chapter Street London SW1P 4NP United Kingdom T. +44 (0) CIMA Zambia 6053 Sibweni Road Northmead, Lusaka Zambia T (211) E. ethics@cimaglobal.com February 2014