The Emirates Association for Accountants and Auditors (EAAA) was established in 1997 and has since has been the only professional accountancy organization in the United Arab Emirates (UAE) bringing together accountancy professionals from different segments of the profession and nationalities, providing training and guidance, advocacy and support to its members. Over this time, the Board and management has built sound internal governance systems and have actively supported the adoption of international standards and best practices in the UAE, creating dialogue and understanding across numerous stakeholder groups and regulators.
With steady membership growth and increasing visibility of the accountancy profession in the UAE as a result of EAAA activities, it was time to step up. In 2020, EAAA started its journey to IFAC membership. The first step was becoming an associate member and committing to comply with the IFAC Statements of Membership Obligations. Since 2020 a number of processes have been reviewed and enhanced as part of that commitment and one of the most significant areas reviewed was the Investigation and Discipline (I&D) process.
Building a Robust I&D System
The I&D process in the UAE is overseen by the Ministry of Economy and a number of other stakeholders but covers only auditors. EAAA saw an opportunity to create its own processes to address the varied profiles of its members, not just its members who are auditors.
It was important to start with laying down the ground rules and establishing regulations for the investigation and discipline and appeals processes. The regulations outline the processes and key steps in detail, providing guidance to EAAA staff, investigation and disciplinary committees, and appeals tribunal members on what needs to be done, how and within what timeframes. Clear guidelines were set for the complaints process; one of the triggers of investigations is a complaints form filed by an EAAA member or the general public. The complaints form is supported by guidance on acceptable reasons for filing a complaint, potential sanctions and a workflow of the complaints procedure established and documented in the regulations. The regulations also cover areas such as conciliation, independent review, reporting, accountability and continuous improvement of the processes. The regulations were approved by the EAAA Board in early 2024 and came into effect in the second quarter of the year by publication on the EAAA website and communication to members.
In accordance with the requirements of SMO 6, Investigation and Discipline, EAAA has established a separate committee for investigation, discipline and an appeals tribunal to ensure that conflict of interest matters are addressed. To enable this structure to operate, charters for each committee and the tribunal were developed establishing the purpose, authority, structure, governance, and responsibilities of these bodies. To compliment the charters, Terms of References were also developed to enable effective and efficient recruitment of candidates for the committees on an as-needed basis, ensuring they have the right set of skills and competencies for a fair and objective process. EAAA takes ethics and independence very seriously. As a demonstration of this commitment, independence declarations were also put in place for each committee and tribunal members to sign ensuring that no conflicts of interest exist and the proceedings are fair.
Building Partnerships
In many cases, PAOs look to establish an automated case tracking system to ease the process of registering and monitoring the progress of cases. However, this is quite costly and the investment may not be feasible for a smaller PAO such as EAAA which doesn’t see a great number of cases annually. In order to decide what approach to use and the system to implement, EAAA had an opportunity to leverage IFAC’s member network and consult with a member of the PAO Development & Advisory Group, the Institute of Certified Public Accountants Rwanda (ICPAR).
As a result of this knowledge-sharing initiative, EAAA has established an agile and easy-to-use tracking system in MS Excel comprising of a case registration log, complaints, conciliation, investigation, discipline and appeals checklists to ensure that no critical steps and actions are missed in the process. It has also adopted a monitoring log which follows cases through every step from first contact to closure. The system is straightforward, with in-built checks and controls and is fully aligned with the EAAA’s regulations.
Looking to the Future
Although a great extent of work has been done so far, it is not yet complete. The next steps for EAAA are to fully operationalise the new system throughout 2024. This will include continuous member and stakeholder communication, publishing all of the relevant guidance on the website, collecting feedback from users on whether guidance is easy to find and understand, training internal staff to work with complaints and administering the process. The critical aspect of operationalisation is rolling out the system in practice when the next case is registered. This test drive of the I&D system allows EAAA to identify any areas which need to be amended, such as timeframes or particular sections of the workflow. At the end of the year, information gathered as lessons learnt from the pilot phase will create input into system improvement for next year. thus bringing to life the continuous improvement programme as outlined in the I&D regulations.