The APCC Professional Standards

The APCC is developing a framework of Professional Standards setting out best practice guidance for compliance consultants. These Professional Standards are to be adapted to meet particular client circumstances and are not intended to be rigid statements of required conduct.

The Professional Standards framework covers the following areas:

• Professional conduct
• Experience and qualifications
• Healthcheck reports to clients
• Procedures on change of appointment

Professional Standards will be developed in other areas as the need for them is identified. Members are therefore encouraged to enter into an active dialogue with the APCC when they identify such a need. In addition each member firm and their personnel are expected to comply with the Code of Ethics.

Each Professional Standard is prepared in draft form and issued to members for comment. These comments are then used to update the draft and where the comments are substantive the consultation process is repeated until broad agreement is reached. The Professional Standard is then adopted by the Steering Council and member firms are notified accordingly.

Professional conduct: This standard was adopted with effect from 9 March 2010. The purpose of these Standards is to provide guidance to Members Firms on the minimum standards that the Association expects all its members to meet on a continual basis.

Experience and qualifications. These are recommended minimum standards for the experience and qualifications of members consultants. The APCC considers that each member firm should maintain an experience and qualification matrix (or equivalent) which documents that within the firm it has sufficient expertise to support the different areas in which it provides advice.

Healthcheck reports to clients: This standard was adopted on 10 January 2007 with effect from 1 February 2007. The need for this standard was identified when it became clear that the scope of these reports and any limitations on the scope (either due to specific client instructions, commercial pressures or other reasons) was causing confusion in the market. In particular the FSA view of what constituted a health check report, which in general is a full scope review of all compliance areas within a regulated firm, was not necessarily fully communicated to regulated firms. Regulated firms have in certain cases relied on healthcheck reports without recognising the impact of scope limitations. Healthcheck reports themselves do not always set out any applicable scope limitations and this has allowed users of the reports to over-interprete the findings of these reports.

Procedures on change of appointment: This standard was adopted by the Steering Council in September 2006. The standard is to ensure that where a compliance consultancy firm ceases to act for a client due to a professional disagreement (e.g.. the client disagrees with the advice given by the consultancy firm or accepts the advice and refuses to act on it) that there is a procedure in place for the material facts relating to an engagement to be communicated to the succeeding consultancy firm.