Conflicts of Interest and Ethics Policy for Accountancy Firms

A firm-wide ethics policy built on the fundamental principles – threats and safeguards, conflict checks and consent, gifts and inducements, fees and commissions, PCRT, NOCLAR and bribery – with forms and registers.

Editable Word document
14
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

Conflicts of Interest and Ethics Policy for Accountancy Firms

About this document

What it’s for

A policy and procedure that puts your professional body’s code of ethics into practice in a small or medium accountancy or bookkeeping firm. It explains how the firm identifies and manages conflicts of interest and other ethical threats, and includes a conflict check form, registers, an annual ethics declaration and a client consent letter.

When to use it

  • As the firm’s written ethics and conflicts policy
  • At client take-on and whenever a new matter could create a conflict
  • For annual staff declarations and monitoring visits

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  1. Purpose
  2. Scope
  3. Definitions
  4. The fundamental principles
  5. Threats and safeguards
  6. Roles and responsibilities
  7. Client acceptance and continuance
  8. Identifying conflicts of interest
  9. Evaluating and managing conflicts
  10. Disclosure and consent
  11. When the firm will not act
  12. Personal interests of staff
  13. Gifts, hospitality and inducements
  14. Fees, commissions and referrals
  15. Tax work and PCRT
  16. Non-compliance with laws and regulations (NOCLAR)
  17. Bribery and facilitation of tax evasion
  18. Raising concerns and getting advice
  19. Breaches
  20. Records
  21. Training, monitoring and review

Also included

  • Consent

How to complete it

  • Insert your professional body and the name of the Ethics Principal
  • Set the limits for gifts and hospitality in clause 13
  • Adapt the examples in clause 8 to the work your firm does
  • Train all staff and keep the registers up to date

Key points to check

  • Codes of ethics are updated regularly – ICAEW updated its code again in 2026 and a new PCRT applies from 1 January 2026
  • Audit firms must also apply the FRC Ethical Standard

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

£20

for every document in this category

Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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