Professional behaviour and the junior accountant: workplace scenarios and where the line is drawn

Professional behaviour and the junior accountant: workplace scenarios and where the line is drawn

Part 2 of a three-part series on professional behaviour and conduct for junior accountants

The first blog in this series explored the changes made to the ICAEW Code of Ethics in 2025 and the ICAS Code of Ethics 2026, and the growing focus on professional behaviour within the accountancy profession. In particular, it considered the revised professional behaviour principle, the concept of “professional life” and the objective standard of the reasonable and informed third party that now sits at the heart of the framework.

This series is intended to help junior accountants understand what those developments mean in practice. This second blog focuses on conduct in the workplace and considers the types of situations in which questions of professional behaviour may arise when interacting with colleagues and others during the course of day-to-day working life. The final blog in the series will examine a different issue; where the boundary lies between professional and personal life, and the extent to which conduct outside the workplace may nevertheless attract regulatory scrutiny.

As matters currently stand, there is relatively little accountancy-specific authority considering the revised professional behaviour provisions. Whilst the types of conduct most obviously capable of attracting regulatory scrutiny are not difficult to identify, there remains limited guidance on where the boundaries will be drawn in less clear-cut workplace situations. That uncertainty is likely to persist until a body of disciplinary decisions emerges under the new regime.

Other professional regulators have already grappled with similar questions. In the legal sector, for example, the SRA has shown a willingness to scrutinise the conduct of junior professionals notwithstanding evidence of workplace pressure, poor supervision or difficult workplace cultures. The fact that an individual is junior does not automatically insulate them from regulatory scrutiny, even where those wider factors form part of the factual background.

The examples below are not intended to suggest that disciplinary action would inevitably follow. Rather, they illustrate the types of workplace situations in which questions about professional behaviour may arise and some of the factors that a regulator may take into account when assessing them.

Repeatedly undermining a colleague

A junior accountant works closely with another member of their team on client matters. Following a disagreement about a piece of work, the accountant begins making disparaging comments about their colleague to others within the department. They repeatedly tell colleagues that the individual is not competent, cannot be trusted with client work and is unlikely to progress within the firm. Although the comments are not made directly to the colleague concerned, they become widely known within the team.

One of the examples of bullying identified in ICAEW’s guidance is “regularly undermining someone“. That example is notable because it captures conduct that may not always appear serious when viewed in isolation. A single critical remark about a colleague is unlikely to attract regulatory attention. A sustained pattern of comments that are designed to, or have the effect of, damaging a colleague’s standing within the workplace may be viewed differently.

The focus of the professional behaviour principle is not simply whether the conduct is unpleasant or unprofessional. ICAEW explains that members are expected to treat others fairly and with respect and dignity in their professional lives. The guidance further notes that behaviours such as bullying are taken seriously because they can undermine ethical cultures, damage trust between colleagues and ultimately erode confidence in the profession.

Whether disciplinary action would follow would inevitably depend on the facts, including the frequency of the comments, the context in which they were made and their impact on the individual concerned. Nevertheless, this type of scenario illustrates how professional conduct concerns can arise from the way colleagues are treated within the workplace, even where there is no dishonesty, client loss or technical failing.

Conduct that becomes part of the culture

A junior accountant joins an established team in which one colleague is frequently the subject of comments relating to their nationality. The remarks are often initiated by more senior members of the team and have become a routine feature of workplace interactions. Over time, the junior accountant begins participating in the same exchanges. No concerns are raised initially, but a complaint is eventually made.

One of the difficulties with situations of this nature is that the conduct rarely develops overnight. It becomes embedded in the culture of the team and may come to be viewed as normal, particularly where more senior colleagues are involved and no concerns have previously been raised.

The revised professional behaviour principle is framed by reference to fairness, respect and dignity. ICAEW’s guidance also refers specifically to harassment and unfair discrimination and notes that conduct may be assessed not only by reference to legal definitions but also according to the ordinary meaning of those terms. The focus is therefore not solely on whether conduct is unlawful, but whether it is consistent with the standards that a reasonable and informed third party would expect of a member of the profession.

That does not mean that context becomes irrelevant. On the contrary, factors such as who initiated the comments, how frequently they occurred, whether they were directed at a protected characteristic and the extent of the junior accountant’s involvement are all likely to be important. Equally, the fact that conduct forms part of an accepted workplace culture is unlikely to be a complete answer if the behaviour itself is inconsistent with the standards expected by the profession.

One of the underlying messages emerging from the ICAEW guidance is that workplace culture matters. The examples of bullying, harassment, victimisation and discrimination are not included because they affect technical competence. They are included because of their potential to undermine ethical cultures, trust and confidence within the profession itself.

Abusive communications with colleagues

A junior accountant becomes involved in a disagreement regarding responsibility for a matter. What begins as a dispute about workload develops into a series of increasingly hostile emails. Over a number of weeks, the accountant sends emails containing expletives, questions the competence of colleagues and copies members of the wider team into the correspondence. The accountant subsequently leaves the firm and sends a further email to their former manager containing abusive language and personal insults.

ICAEW has published a case study that provides a useful indication of how conduct of this nature may be approached. The case concerned a manager who, following criticism from their supervisor, sent a series of emails criticising members of their team, including one email accusing a colleague of incompetence. After leaving the firm, the individual sent a further email containing foul language to a former supervisor. ICAEW’s Conduct Committee concluded that the behaviour occurred in the context of the individual’s professional role because it involved workplace relationships and colleagues. It further concluded that the conduct demonstrated a lack of respect towards others and was serious enough to justify disciplinary action.

A number of features of the case study are noteworthy. First, the Committee attached significance to the repeated nature of the conduct, observing that the emails had been sent on more than one occasion. Secondly, it considered that the language used undermined workplace relationships, despite there being no threats or discriminatory language. Finally, the fact that the individual had resigned, and was engaged in an employment dispute with their former employer, did not prevent ICAEW from considering the conduct from a regulatory perspective.

That final point is particularly important for junior accountants to become familiar with. Employment issues and regulatory issues frequently overlap, but they are not the same thing. Leaving a firm does not necessarily bring regulatory scrutiny to an end. A grievance may be resolved, an employment claim may settle, or an individual may move to another employer, but questions regarding compliance with professional standards can continue long after the employment relationship itself has ended.

This is one of the clearest examples of how professional regulation differs from ordinary workplace disputes. The regulator’s concern is not simply whether the employment relationship has broken down, but whether the conduct itself is consistent with the standards expected of a member of the profession.

The duty to report

One issue that junior accountants can easily overlook is that the regulatory implications of workplace conduct are not necessarily confined to the individuals directly involved. In some circumstances, it may not only be the perpetrator of the conduct, or the person on the receiving end of it, who has regulatory obligations to consider. Those who witness conduct, become aware of it, or are informed about it may themselves have reporting obligations under the rules of their professional body.

Both ICAEW and ICAS impose duties to report potential misconduct. Under ICAEW Disciplinary Bye-law 6.1, members, firms, affiliates and other relevant persons must report matters which may indicate that they or another member, firm, affiliate or relevant person may be liable to disciplinary action by ICAEW. Similarly, under ICAS Investigation Regulation 3.1, members are required to report facts or matters indicating that another member, affiliate, CA student or firm may be liable to disciplinary action. ICAEW’s guidance makes clear that this can extend to workplace misconduct, including behaviour such as bullying, harassment and abusive or intimidating conduct towards colleagues.

This has important implications for junior accountants. If, for example, a colleague is repeatedly subjected to discriminatory comments, is being bullied by a manager, or is receiving abusive communications of the kind discussed earlier in this article, the issue may not simply be a matter for those directly involved. Depending on the circumstances, those who become aware of the conduct may need to consider whether it gives rise to reporting obligations under the relevant professional rules.

The key point is that professional behaviour obligations are not solely concerned with avoiding misconduct yourself. They may also require difficult decisions about how to respond when concerns arise in relation to others. As the profession’s approach to workplace conduct continues to develop, understanding those reporting obligations is likely to become increasingly important.

The challenge for junior accountants

The common thread running through these examples is not that disciplinary action would inevitably follow. Rather, each demonstrates how questions of professional behaviour can arise from interactions that many accountants would historically have regarded as workplace issues rather than regulatory ones.

For junior accountants, the difficulty is that many of the boundaries remain unsettled. The revised provisions are still relatively new, there is limited disciplinary authority to provide guidance, and expectations around professional conduct continue to evolve. As a result, the answer to whether particular behaviour is capable of attracting regulatory scrutiny will often depend heavily on context, proportionality and the facts of the individual case.

The final blog in this series will consider what is likely to be the most difficult aspect of the new framework: the distinction between professional and personal life, and the extent to which conduct outside the workplace may nevertheless become a matter of regulatory interest.