The National Conference of CPA Practitioners (hereinafter ‘NCCPAP’) has established a Code of Conduct addressing ethics and conflicts of interest. This Code requires directors, officers, committee chairs and committee members, and employees (hereinafter ‘associates’) to observe high standards of business and personal ethics in the conduct of their duties and responsibilities.
All associates must practice honesty and integrity in fulfilling their responsibilities. They also must comply with all applicable laws and regulations.
Reporting Responsibility
It is the responsibility of all associates to comply with the Code and to report violations or suspected violations in accordance with this Whistleblower Policy.
No Retaliation
No associate who in good faith reports a violation of the Code shall suffer harassment, retaliation or other adverse consequence. An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.
This Whistleblower Policy is intended to encourage and enable associates to raise serious concerns within the Organization prior to seeking resolution outside the Organization.
Reporting Violations
The Code addresses the Organization’s open door policy and suggests that associates share their questions, concerns, suggestions or complaints with someone who can address them properly. In most cases, a member of the Ethics Committee is in the best position to address an area of concern. However, if an associate is not comfortable speaking with a member of the Ethics Committee, or is not satisfied with the member of the Ethics Committee’s response, he or she is encouraged to speak with the President.
For suspected fraud, he or she should contact the Ethics Committee directly.
Ethics Committee
NCCPAP’s Ethics Committee is responsible for investigating and resolving all reported complaints and allegations concerning violations of the Code and, at its discretion, shall advise the President. The Ethics Committee has direct access to the Board of Directors and is required to report to the Board at least annually on compliance activity.
Accounting and Auditing Matters
The Finance Committee of the Board of Directors shall address all reported concerns or complaints regarding corporate accounting practices, internal controls or auditing. The Ethics Committee chair shall immediately notify the Finance Committee of any such complaint and work with the Finance Committee until the matter is resolved.
Acting in Good Faith
Anyone filing a complaint concerning a violation or suspected violation of the Code must be acting in good faith. He or she must have reasonable grounds for believing the information disclosed indicates a violation of the Code. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a basis for review by the Ethics Committee.
Confidentiality
Violations or suspected violations may be submitted on a confidential basis by the complainant or may be submitted anonymously. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.
Handling of Reported Violations
The Ethics Committee chair will notify the sender, acknowledging receipt of the reported violation or suspected violation within five business days when practical. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.
Ethics Committee Chairperson
National Conference of CPA Practitioners