8 February 2010
Ms Kate Spargo
Chairperson
Accounting Professional & Ethical Standards Board
600 Bourke Street (Level 7)
MELBOURNE VIC 3000
Dear Ms Spargo
Consultation Paper: Proposed Revision of APES 110
Code of Ethics for Professional Accountants
The Group of 100 (G100) is an organisation of chief financial officers from
Australia’s largest business enterprises with the purpose of advancing
Australia’s financial competitiveness. The G100 is pleased to provide comments
on the Consultation Paper.
Question 1
- Mixture of mandatory requirements and guidance: In accordance with
APESB drafting conventions, should the revised APES 110 be formatted so that
mandatory requirements appear in separate paragraphs to guidance?
The G100 believes that the APESB should not depart from the way in which its
standards are drafted and formatted. It is important for ease of
understanding by constituents that a consistent and recognizable style is
used. Accordingly, the separation of mandatory requirements from guidance
makes the standards clearer for constituents.
- Defined terms: Should the revised APES 110 use IFAC defined terms, use
defined terms tailored to the Australian environment, or, where applicable, use
defined terms which are consistent with those used in Australian Auditing
Standards?
As a standard applying in Australia, the G100 believes that defined terms should
be refined so that they reflect the environment in which the standards are to be
applied. This would also facilitate understanding and implementation by
constituents.
- Capitalisation of defined terms: Should defined terms be differentiated
from non-defined terms by capitalizing defined terms in the revised APES
110?
Yes, if this is consistent with the APESB drafting convention.
- Definition of ‘public interest entity’: Should the revised APES 110 use
the IFAC definition of ‘public interest entity’ or provide guidance on the
application of the IFAC definition in the Australian context or redefine
this term in the Australian context?
The G100 believes that the definition of ‘public interest entity’ proposed
in section 290 of the IFAC Code is acceptable. However, it may be useful to
consider the definition and guidance of ‘public accountability’ used in the
IASB’s standard ‘IFRS and SMEs’ and in the AASB’s proposals in respect of a
revised differential reporting framework.
Question 2
Should specific references to the Corporations Act 2001 and the Australian
Auditing Standards be incorporated into the revised AES 110 where relevant?
Yes. As the standards are to be applied in the Australian environment the
requirements are more meaningful and useful to constituents if relevant
references to the Corporations Act and Australian Auditing Standards are
included.
Question 3
Do you believe sections 290 and 291 of the IFAC Code should be presented
in their current form in the revised APES 110 or should they be restructured to
remove duplication where possible?
The revised APES 110 should avoid duplication and repetition in order to
facilitate readability and understanding by constituents. The G100 believes that
as the standard is issued to be operational in the Australian environment it
should be written in a style which is consistent with other Australian standards
and should be as user-friendly as possible to facilitate readability and
understanding.
Yours sincerely
Group of 100 Inc
Peter Lewis
National President