Julie Baillie FFA, Actuary at Barnett Waddingham
The revision to the Code brings a new emphasis to our responsibility as actuaries to speak up if we believe that a course of action may be unethical or unlawful.
The 'Speaking Up' principle includes reporting other members of the actuarial profession if there appears to be any misconduct or a breach of regulatory or professional requirements. It also includes reporting to any other bodies if behaviour appears to be unlawful or unethical and, of course, to comply with any legal requirements to report matters to regulators or other authorities.
The requirement to speak up in this way was always in the Code, but was included within the compliance principle and required members to “challenge non-compliance by others” and to speak up to “their clients or employers, or both”. Our professional whistleblowing obligations have always been clear and the actions required by the Code to report unlawful behavior have not changed.
The revised Code, however, now separately states that “members should speak up if they believe, or have reasonable cause to believe, that a course of action is unethical or unlawful." This is a broader and stronger directive than in the previous version.
The revised Code . . . now separately states that “members should speak up if they believe, or have reasonable cause to believe, that a course of action is unethical or unlawful." This is a broader and stronger directive than in the previous version.
By creating this new, distinct principle of 'Speaking Up,' the actuarial profession is emphasising to members that we have an explicit responsibility to challenge other people where something is not right. This of course applies where their actions may be unlawful, but also if they are on the right side of the law but their actions may still be unethical.
This is, perhaps, the most difficult principle for us as actuaries to follow – the idea of confronting a boss or a client with a suggestion of wrongdoing, intentional or otherwise, is not a comfortable scenario for most people. It is, however, a necessary principle to make sure that the actuarial profession continues to carry the confidence and respect of our clients, other professionals and the general public.
There have been too many instances in the wider financial environment where practices were not challenged and people at all levels declined to speak up and say when something wasn’t quite right.
At Barnett Waddingham we foster an open culture in which anyone can articulate a concern and nobody is prohibited or penalised for doing so. We have a clear policy on speaking up and many available avenues within the firm to discuss or report any concerns. Our compliance team provides regular comprehensive training on when and how to raise any issues, and as a firm our Barnett Waddingham Values set out our commitment to doing the right thing.
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