Five steps for business continuity amid COVID-19
As a former CFO, I have managed through crises, including the Gulf War, 9/11 and the 2008 financial crisis. The financial disruption of the coronavirus (COVID-19) pandemic is like having all three of those events occur simultaneously. Our entire global economic and social system is operating in uncharted territory.
Amid the uncertainty, the finance function can create value and elevate its role as a strategic business partner. As CPAs and CGMA® designation holders, our training and experience equip us with the expertise and skills to mitigate risks and lead the recovery efforts for our organizations, businesses and communities.
To help guide you, the Association of International Certified Professional Accountants®, the global voice of the AICPA® and CIMA®, delivers the latest news, resources and guidance through our AICPA and CIMA Coronavirus Resource Centers. Visit frequently to stay up to date on the coronavirus and learn about upcoming events, such as the free webcast series I’ll host with finance leaders in the coming weeks. This series will offer expert insights on business planning to help you lead your organization through this crisis.
A five-step plan for business continuity
On my first webcast in this series (also available as a podcast), Chris Kite, Oracle’s VP of Global Strategy, shared her approach to business continuity, which starts with a business continuity plan (BCP). If your organization doesn’t have one, check if it has a disaster recovery plan (DRP) that can be leveraged. If it has neither, it’s time to start fresh. Once you have your BCP, follow these five steps to ensure its effectiveness:
- Conduct a business impact analysis (BIA).
A BIA can help your organization determine and evaluate the potential effects of the coronavirus on business operations. This process involves performing a gap analysis to assess your organization’s readiness for continued operations. When conducting this analysis, consider the impact on the following stakeholder groups:
Employees — Your workforce should be your most important concern. How you manage your staff now can have a long-term impact on employee loyalty and retention. Start by identifying the “critically important” processes and the staff members who execute them. Next, determine if these processes must be conducted on premise or if they can be performed remotely. Also consider any actions that allow most of your organization to work remotely. It’s vital to start building back up capability as it’s possible that a portion of your workforce may get sick because of the virus.
Customers — How your organization responds to and serves its customers now is crucial for building long-term loyalty. One misstep could cause long-term reputational damage. Closely monitor customer debt levels and regularly assess their credit risk. Don’t use standard credit scores that are now not accurate, but unconventional ones that will help you determine if a customer will be a going concern after normalcy returns.
Suppliers — With global supply chains disrupted, you must determine what supplies or suppliers are “critically important” to keep your operations running. Review all your supplier contracts, understand the implications and determine if there are other ways to continue your operations if one of your suppliers cannot deliver goods. Now is the time to rethink and reconsider everything. This is your opportunity to challenge conventional thinking. Encourage innovation and creativity.
- Build scenarios (modeling).
Next, you’ll want to create models for “worst” and “most-likely” case scenarios. This provides an adequate range of outcomes for the business to consider. For example, if you look at your key stakeholder groups and the risks you have identified for each, you should be able to identify possible strategic, operational and financial outcomes for the next three, six or 12 months. The CGMA scenario planning tool is a great resource to guide you through this process. Don’t forget to also look at the upside risks. There might be alternate business models or new ways to serve your customers.
- Perform risk analysis and mapping.
In this step, you should consider scenarios (created in step two above) to help you identify new risks. This will help you build robust scenarios. Consider also other potential risks — including financial, strategic, operational and external — and the probability of occurrence. The CGMA Risk Heat map can guide you with this effort.
- Ensure organizational alignment and communication.
If your organization doesn’t yet have one, create a cross-functional pandemic response team. This will ensure organizational alignment around key objectives. You’ll also want to make sure approvals are in place to execute the continuity plan that conforms with governance requirements.
Communication with stakeholders is also a vital step of every BCP. Identify the content and frequency with which you want to communicate with your stakeholder groups. It’s extremely useful to create specific landing pages for employees, customers, investors, etc., with resources and guidance.
- Develop an action plan with continuous monitoring.
An effective BCP also focuses on key performance indicators (KPIs) of priority processes. Increase the frequency of measuring and monitoring liquidity, sales, stock, etc. to daily and/or weekly. Leverage data feeds for rapid responses to changing risks. Attempt to enable continuous forecasting in key functions and keep adjusting. As already mentioned, liquidity is the key. Also important is the workforce, the ability to continue to serve the customer, as well as maintaining the production lines and the supply chain.
The Association is here for you.
We know your organizations, businesses and communities depend on your guidance during these challenging times. We’re here to help. If you have any questions or need anything, please don’t hesitate to contact our Global Engagement Center. We’re proud of the work you’re doing and honored to serve you.
Ash Noah, CPA, CGMA, FCMA, VP - Managing Director- MA Learning, Education & Development, Association of International Certified Professional Accountants
Free AICPA resources to help you navigate COVID-19
The coronavirus (COVID-19) pandemic is causing enormous consequences around the globe, and we know many of our members are experiencing uncertainty and concern for what’s next. The Association of International Certified Professional Accountants, the global voice of the AICPA and the Chartered Institute of Management Accountants (CIMA), is here to help you through these challenging times.
Your firms, organizations, clients and communities are depending on your expertise during this crisis. And it’s our job to make sure you have the help and information you need to manage through this pandemic.
We created the AICPA Coronavirus Resource Center to provide you with the latest news, resources, event information and guidance to help you advise your organizations, clients and customers. You’ll also find resources to help you and your staff better manage our new way of working. Bookmark the page and visit often for the latest updates on COVID-19 and new learning opportunities like these:Free CPE webcasts and Livestreams
Our webcasts and social media livestreams provide you with expert insights on topics such as business continuation, risk management, remote auditing and more. If you can’t make the live session, a video recording is always available on the AICPA Coronavirus Resource Center. Here are a few upcoming events:
- Conducting Remote Audits in Uncertain Times — Gain insights from AICPA Chief Auditor Bob Dohrer, CPA, and Andrew Prather, CPA, on how you can conduct a remote audit. March 25, 1-2pm ET, April 1, 12-1pm ET or April 10 from 11-12pm ET. Offers 1 free CPE credit.
- Understanding Market Implications and Bringing Calm Amid Chaos — Hear from top CPA financial planners on how you can best manage physical and economic stresses associated with the pandemic — both your own and your clients’. April 1, 4:30-5:45pm ET, April 6, 1-2:15pm ET, April 13, 1-2:15pm ET. Offers 1.5 free CPE credits.
- Pandemic Risk Mitigation and Practical Considerations for CPA Firms — CPA firms face significant emergency planning issues surrounding COVID-19. Hear a top expert discuss what firms face with insurance, business continuity, privacy/security and more. March 27, 12-1pm ET, March 30, 2-3pm ET or March 31, 3-4pm ET. Offers 1 free CPE credit for AICPA members.
Our collection of recorded conference sessions offers guidance on a range of topics, including managing remote teams, team morale and how to deal with a complex business interruption. These sessions also give you a feel for our virtual conference experience. The following sessions are available exclusively to AICPA members:
- Planning for Self-care — Leaders must take care of their mental, physical and financial health to run a profitable organization. Learn techniques and programs to reduce work stress, boost productivity and increase profits.
- Small Firm Technology Solutions — New technology can reduce firm risk and increase productivity and flexibility. Explore the latest audit and tax technologies, including collaborative accounting, payroll, SALT, document management, portals, eSignature and email encryption.
- Business Interruption Accounting for Causality — There’s value to considering causality when measuring business interruption losses. This video explains the purpose of business interruption insurance policies and illustrates the best ways to isolate cause and effect when measuring losses.
9 actions the government must take now to support businesses and employees
The American Institute of CPAs® is calling on Congress and the Trump administration to take nine key steps to protect U.S. businesses and employees struggling due to the impact of the coronavirus (COVID-19) on the economy.
In speaking with CPA firms, businesses and AICPA® members across the country, the AICPA identified the below actions as most urgent and necessary for the following groups. Note that the information on current federal activity is current as of the publication time of this blog (24 March 2020, 9am ET).
1. Suspend all required debt payments, including principal and interest, for mortgages and small and medium-sized business loans.
Further, the government should ease bank capital and provisioning requirements during the crisis and should establish a federal guaranty program so that banks do not have to set aside capital or recognize losses.
Current federal activity — Consideration is underway for a third stimulus bill to address the economic fallout from the coronavirus outbreak. The Senate “Phase III” legislation creates a fund for small-business relief. The fund will provide federally backed loans to forgive debts such as mortgages or other payments. If employers keep their workers on the payroll, the loans don’t need to be repaid. The House introduced legislation that would suspend the requirement to pay Small Business Administration (SBA) loans for six months, as well as establishes grants and additional disaster loan opportunities for small businesses that can demonstrate harm.
Notably, the Senate bill also allows for a six-month delay of repayment for federal student loans and allows the Secretary of Education to extend that for an additional three months. This bill is currently under Congressional consideration.
Finally, the Federal Housing Finance Agency ordered lenders to offer reduced payments or — in some cases — a pause on mortgage payments. Assistance requires outreach to the mortgage servicer based on the customer’s situation.
2. Waive all loan covenants for six months.
Additionally, the AICPA recommends waiving any fees or additional charges associated with loan covenant violations, waivers and credit agreement modifications.
Current federal activity — None, although other groups have advocated for similar measures. The Bank Policy Institute has urged the Federal Reserve to ease capital requirements and pull back on stress testing during the pandemic period. Additionally, prudential regulators are encouraging banks to lend to lower-income Americans. In a joint statement, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) said increased access to income by lower-income individuals would reflect well on the banks’ CRA score.
3. Allow three-year net operating losses (NOLs) carrybacks.
A depreciation carryback can be monetized more quickly, giving businesses faster access to much-needed money to continue operations.
Current federal activity — Sen. McConnell’s Phase III bill includes a provision temporarily suspending the existing NOL rules and allowing for carrybacks.
4. Establish a federal payroll grant to fund small business.
Small businesses are the heart of the American economy, but many are struggling to make payroll as the country takes the necessary steps to address the coronavirus pandemic. The AICPA is leading a coalition urging the Trump administration and Congress to create a payroll fund that can be distributed to small businesses.
Current federal activity — Efforts within the administration are ongoing to create a payroll mechanism to rapidly inject capital into the economy.
5. Freeze rent or mortgage payments.
If a small business is shut down, its rent or mortgage payments should be frozen until they can re-open for business. This would keep cash available to small businesses that may need immediate funds elsewhere.
Current federal activity — Sen. McConnell’s and Speaker Pelosi’s Phase III bills each include Small Business Administration loans for businesses with 500 or fewer employees, and these loans may be used to pay mortgages or rent. Additionally, if an employer retains employees from March 1, 2020, through June 30, 2020, the portion of the loan used for payments on pre-existing debt will be forgiven. The House bill would also create a fund to assist homeowners with mortgage and utility payments.
Finally, the U.S. Department of Housing and Urban Development is suspending foreclosures and evictions for mortgages insured by the Federal Housing Administration.
6. Provide relief from banking and credit card payments.
Similarly, to keep cash in the hands of small businesses, all debt and credit card payments should be frozen.
Current federal activity — The two stimulus bills signed into law (H.R. 6074 and H.R. 6201) do not address bank or credit card payments. The third stimulus bill, which is rapidly evolving in the Senate, does not directly address banking and credit card payments.
Outside of government action, many credit card companies and larger financial institutions are encouraging customers to call and discuss options. American Express, Capital One, Citi, Apple Card and Bank of America are allowing customers affected by COVID-19 to skip March payments, but customers must call the company to get details, as not all companies are allowing skipped payments without accruing interest.
7. Expand access to unemployment benefits.
Congress should increase federal support to states’ unemployment programs. Additionally, states should lower restrictions to provide employees with a quick route to these benefits. The Administration and states should also allow companies to supplement unemployment with wages to ensure employees have enough funds to meet their needs.
Current federal activity — The Phase II bill that the president signed into law provides $1 billion in emergency grant funding to states for processing and paying unemployment insurance (UI) benefit activities. Half of that funding would be allocated toward staffing, technology, systems and other administrative costs, while the other half would be for emergency grants to states that experienced a 10% or more increase in unemployment.
Sen. McConnell’s Phase III bill provides funding to pay for the first week of unemployment benefits if a state decides to pay a recipient as soon as they are unemployed rather than waiting a week until they are eligible for benefits.
The House and Senate bills provide an additional $600 per week for recipients and 13 weeks of benefits for a recipient after state unemployment is no longer available.
The House and Senate Phase III bills provide funding for short-term compensation in which rather than laying off employees, an employer reduces hours and the employee receives pro-rated unemployment benefits. The bill provides 100% of the costs for short-term compensation.
8. Support employees in the hospitality industry.
The hospitality industry has been one of the hardest hit by the current economic situation. U.S. Travel estimates the industry will lose $355 billion, 4.6 million employees will be out of work, and unemployment will rise to 6.3%. Large companies, trade and professional associations and unions should be allowed to create a charitable fund for these employees. Funds should enable both companies and individuals to submit donations that help employees who are no longer get a paycheck, and organizations should be allowed to report these donations as a general business deduction.
Current federal activity — The hospitality industry has called for a major cash infusion from the federal government — $100 billion to retain workers and $50 billion to service debt. Neither the Senate nor the House “Phase III” bills under consideration specify assistance to the hospitality industry. The Senate bill provides $425 billion in loans, loan guarantees and investments using the Federal Reserve’s lending mechanisms to eligible businesses, states and municipalities to aid distressed sectors of the economy. The House legislation has several provisions directed at small businesses affected by the crisis, including $100 billion in grants, $200 billion in zero-interest, zero-fee loans, $7 billion in low-interest loans, and debt relief from SBA loans.
To date, there have not been any policy proposals to create charitable funds for hospitality industry employees.
9. Expand access to 401(k) assets.
The administration should:
- Forgive the 10% early withdrawal penalty on 401(k) early distribution in 2020;
- Allow for repayment within one year rather than 60 days, with no penalty or interest;
- Waive the contribution limitation on funding 401(k) plans back to regular levels (before the administration’s declaration of a national emergency); and
- Allow the pandemic to quality as an automatic “triggering event” for 401(k) loans.
Current federal activity — Both the Senate and House “Phase III” bills include provisions to provide access to certain retirement fund assets. The Senate bill waives the required minimum distribution rules for certain defined contribution plans and IRAs for calendar year 2020. The House bill waives the 10% early withdrawal penalty for distributions, allows individuals three years to repay distributions and include those distributions in income ratably over three years, increases loan limitations to the lesser of $100,000 or 100% of participants’ vested balance and extends loan repayment start dates to begin after one year.
10 ways to stay social at a distance
To limit the spread of COVID-19, we all have to do our part. For the majority of Americans, this means working or schooling from home, limiting all discretionary travel – including social trips – and avoiding groups of 10 or more.
For some, a few days at home may be a welcome break from the daily grind. But if not managed correctly, increased time at home during these stressful, uncertain times can take a toll on your mental and physical health. The American Psychological Association reports that social isolation can lead to poor sleep, poor cardiovascular health and depressive symptoms, as well impairing our ability to focus and manage emotions. While staying home and practicing social distancing are critical to reducing the spread of the virus, it’s also important to take care of your mental health.
One of the best ways to do this is to stay connected with your family, friends and colleagues. To keep that connectivity while you’re at home, the AICPA Insights team offers these suggestions to help you stay social – at a distance. 1. Virtual water cooler / happy hour
– One of our favorite aspects of working in an office is impromptu bonding time with coworkers. That’s harder to do when separated, but with a little planning, it can still happen. Set up 10 or 15-minute video or phone calls with colleagues to chit-chat while you enjoy your morning water or coffee.
At the end of the workday, shoot the breeze from a safe distance at a virtual happy hour. Remotely bring your coworkers together to talk about your day, your favorite drink or anything else. Please note this happy hour is BYOB (bring your own beverage) and has the potential to evolve into virtual karaoke if it goes on long enough.
If you miss your neighbors, coordinate a time after the workday where you can walk out your front doors and toast each other from a safe distance! 2. Bond over food
– Many people find that food can lift their spirits during stressful times (hence the term “comfort food”). Organize a digital potluck where you can exchange your favorite recipes with colleagues and try something new. You can kick it up a notch by having a co-worker share their favorite recipe via video conference from their own kitchen. Everyone else can follow along for step-by-step cooking instructions.
Cooking not your thing? Support your local restaurants with a digital dinner date! Many restaurants are struggling to the point that they have to furlough staff or even let them go entirely. Offer your support by ordering from their delivery menu. Take it a step further by coordinating with a group of friends to all order from the same restaurant at the same time. Once all the food has been delivered to each location, hop on a video chat and enjoy your meal together.3. Start a club to share what you’re watching / reading
– Don’t know what to watch? Have a great suggestion? Start a group where you can share your favorite TV and movie recommendations. You can even set up calls to discuss and review selections together. If you want to get really creative, coordinate starting the movie at the exact same time. That way you can live chat throughout the movie. There are several great apps, extensions and websites that can help you sync up streams
across the Internet.
Now is also a great time to finally pick up that book you’ve been wanting to read. While you’re at it, why not make it a group read? Reach out to a few friends and colleagues to see if they want to join. As you work through the story together, you can schedule times to hop on a call and discuss your thoughts on the most recent chapter.4. Enjoy the arts with a night at the opera or virtual museum tour
– Seize the opportunity to watch some of the world’s greatest operatic performances from the comfort of your own couch with free streamed concerts from the Metropolitan Opera House in New York City. The “Nightly Met Opera Streams” begin at 7:30 p.m. ET each night on the Met's homepage
. The performances remain available for 20 hours and are also available on the Met Opera’s On-Demand apps.
You can also experience the best museums, from London to Seoul. Many top museums from around the world are offering free online tours
to help people cope with staying home. Go alone for a relaxing and personal experience, or coordinate with friends to take a remote tour together and share in the world’s greatest art.5. Go on safari with the Cincinnati Zoo
– Every day at 3:00 pm ET, the Cincinnati Zoo invites people to join them on Facebook Live
for a fun and educational tour. Each live broadcast highlights one of their amazing animals and includes an activity you can do from home. The first episode featured the world’s most famous (and adorable) hippo, Fiona
.6. Team trivia break
– Ever wanted to host your own trivia show? Now’s your chance. Get a group together at a set time each week for a fun trivia competition via video call. Participants can ‘buzz’ in by typing a letter into the chat function of your group meeting. Whoever got their name into the chat window first can then give their answer on video. Each week, the rotating host gets to choose the topics and questions. Play for a prize or just play for fun!7. Meet the family video calls
– Embrace being home with your family during the workday and schedule a video call to introduce your cohabitants to your coworkers. Pets are absolutely included and strongly encouraged.8. Virtual jam session
– If you’ve got a guitar or keyboard lying around, team up with friends on a video conferencing platform to host a virtual jam session. Play for yourselves or invite more friends to join in for some free live entertainment.9. Home fitness club
– Physical fitness is important for keeping anxiety at bay and maintaining a sense of normalcy and well-being. You don’t need a gym to be fit — get your workout in at home. If you like being led by an instructor, there are a wide range of paid and free online streaming services to choose from. Get a group together, choose a program and coordinate a time each day you all plan to do the workout from home. After each class, you can message each other about your favorite (or least favorite) part.10. Be good company
– Many people would really just appreciate someone to talk with. Reach out to friends and family to check-in, catch-up and keep them company. You can even help out those with kids by volunteering to read their children a story via a video call while they take what is likely a much-needed and much-appreciated break.
Don’t want to talk on the phone? Consider sending a good old-fashioned handwritten letter. Something about the experience of writing things out by hand makes it feel more considerate and personal. Sure, it takes a while to get there, but the effort makes you think much more about what you want to say and how best to say it.Bonus: help a neighbor in need
– In times like these, taking care of each other is very important. If you’re low-risk and up-to-date on your current local guidelines for going outside, consider helping an at-risk neighbor in need of a grocery delivery. To add to the social aspect, call them from the store and allow them to walk you through their list. Your contribution helps foster a strong sense of community, and that benefits both yourself and the whole.
You may sometimes feel like you’re in this alone, but these suggestions should remind you that we’re all in this together. Taking care of yourself, your friends and your family all help make for a stronger community. If you ever find yourself feeling overwhelmed, the Center for Disease Control (CDC) has specific resources to help cope with coronavirus anxiety.
Coronavirus: Prepare your clients and protect your practice
March 20 update: Treasury Secretary Mnuchin announced via Twitter on March 20 that the deadline to file returns has now been extended to July 15, along with the previous extension to pay. We continue to urge taxpayers who are anticipating refunds to work with their practitioners as they are able, to file as soon as possible. More information is expected, and we will update you as the details emerge.
March 18 update: Notice 2020-17, Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic, was released on March 18. The notice provides for an extension of time to pay federal income taxes originally due April 15, 2020 until July 15, 2020. The relief is only applicable to individual tax amounts up to $1,000,000, regardless of filing status or up to $10,000,000 for each consolidated group or for each C corporation that does not join in filing a consolidated return. No extension is provided in the notice for the payment or deposit of any other type of federal tax, or for the filing of any tax return or information return. The AICPA continues to work with Treasury for appropriate relief. Continue to check out the AICPA Coronavirus Resource Center for the latest updates and press releases.
The novel coronavirus (COVID-19) has been at the top of minds and dominated news coverage since it was first identified in Wuhan, China, in December 2019.
The coronavirus spread globally since its initial outbreak, and the World Health Organization (WHO) has officially declared it a global pandemic.
Check out this animated map to see its spread.
The coronavirus outbreak is causing noteworthy disturbances to many companies’ operations. Public accounting practices are no different. Fortunately, there are steps that you, as a practitioner, can take to best position your clients and practice to handle the challenges associated with the coronavirus or any unforeseen extraordinary event.
Prepare your clients.
Your clients might ask what they can do in the event they can’t file their tax returns on time.
The AICPA issued a March 10 press release calling for the Treasury Department and the Internal Revenue Service (IRS) to give all taxpayers an automatic extension until Oct. 15 without the need to file any forms or request the extension, along with waiving related fees. The AICPA also recommended an extension of the filing deadlines for businesses.
Considering the president’s declaration of a national emergency, invoking the Stafford Disaster Relief and Emergency Assistance Act, we’re anticipating the Treasury and the IRS will make an announcement this week. This could include an extension of the April 15 filing deadline by as much as 90 days and a waiver of penalties and interest for most taxpayers. Additionally, they’ve indicated they’ll be generous in determining reasonable cause abatement of penalties for taxpayers and tax preparers unable to file promptly.
While we wait for additional decisions from Washington, the extension of time to file is still a prime mechanism already available for taxpayers who need more time to complete their returns. We’ve developed some pointers on how to communicate extension filing with your clients. You can find them in our “Tax extension FAQs for clients” in the Tax Practitioner’s Marketing Toolkit.
While a filing extension doesn’t extend the time to pay, knowing that they have an additional six months to complete their returns will put your clients’ minds at ease. And, if worst comes to worst for some come April 15, there are options available for requesting abatement for failure-to-pay or failure-to-file penalties. Check out the AICPA’s IRS first-time penalty abatement guidance and IRS penalty abatement templates for details.
Bottom line? Plan with your clients. Don’t wait until the last minute to encourage clients who might need to extend their returns to file an extension.
Protect your practice.
Having your whole office out sick will slow practice productivity, failing in service to your clients.
To reduce community spread of the virus in your office, consider implementing remote working options for your employees. This will reduce the exposure and transmission of the coronavirus among coworkers.
You may see other benefits as well. Those working remotely will tell you that the reduction in their daily commutes alone provides them with reduced stressed and leads to a more efficient and productive work day. There are also fewer distractions than in a traditional work environment. Many remote workers even enjoy overall healthier lifestyles, as there is more time for periodic exercise and fresher eating options because workers can prepare meals themselves instead of buying lunch on the go.
And, with technologies such as Zoom, Skype and RingCentral, employees can stay just as connected virtually as they do in person. Here are some more tips on how to make remote working successful in your practice.
Don’t just focus on implementing virtual tools for workers. Establish portals for clients to upload tax documents or download copies of their completed returns and workpapers. This is an added benefit for clients who are unable or unwilling to venture out beyond their comfort zones. This is another way you can do your part to reduce community spread.
The key here is to be proactive and have contingency planning in place for your employees, clients and business. Check out some additional tips and considerations in planning for the coronavirus.
With all the uncertainly surrounding the coronavirus, it can be an uneasy time. Rest assured knowing that the AICPA is here to support members. Make sure to check out information about the coronavirus from reliable sources, such as the Centers for Disease Control and Prevention. And, check out the AICPA Coronavirus Resource Center, stacked with articles, podcasts, a State tax filing guidance for coronavirus chart and other resources to make sure you are up to date on the virus and its potential effects on your clients and practice.
Sarah Shannonhouse, CPA, Manager — Tax, Practice and Ethics, Association of International Certified Professional Accountants