ABSTRACT. This research examines the extent to
which similarities and differences exist in the codes
of professional conduct of certified (chartered)
accountants across the following countries: the United
States, Taiwan, South Korea, Malaysia, Ontario
(Canada), Australia, India, and Hong Kong. These
eight countries exemplify some of the diversity in
economic, political, legal, and cultural environments
in which public accountants practice. The professional
codes of ethics establish the ethical boundary para-
meters within which professional accountants must
operate and they are a function of these environments.
The results of the study reveal that commonalities
exist on some ethical rules indicating that some rules
are indeed “culture free”. Cross-country variations,
however, exist as to the specificity and elaborateness
of the rules. Such variations can be attributed to
cultural and legal differences, as well as the length of
time each professional organization has been in
existence. An understanding of the similarities and
differences in the codes is important to individuals
who may work in these countries. Professional
accountants involved in international business must
understand the implications of the decisions they
make in light of the ethical codes and moral values
of their counterparts in foreign countries. After a dis-
cussion of the similarities and differences in the codes,
the implications of these comparisons for accounting
practice are discussed.
KEY WORDS: Certified Public Accountant, Code
of Professional Conduct, Chartered Accountant
Introduction
Business professionals often have to deal with
ethical problems while carrying out their pro-
fessional activities. Much publicized events such
as the Iran Contra Affair and the Savings and
Loans scandal heightened the level of sensitivity
among the public to the betrayal of public trust
by various professional groups. Any failure by a
profession to hold the public trust may cause the
public to lose its confidence in that profession.
The public accounting profession is no excep-
tion. They, like members of any other profes-
sional group, are expected to uphold certain
ethical standards in their professional practice. As
a result of events such as these, the study and
research of ethical problems in accounting has
attracted greater attention in recent years (e.g.
Mihalek et al., 1987; Likierman, 1989; Stanga
and Turpen, 1991; Gunz and McCutcheon,
1991; Cohen and Pant, 1991; Schweikart, 1992,
Madison and Boatright, 1995, Preston et al.,
1995). While many researchers have addressed
ethical issues in a variety of different countries,
few studies seek to compare similarities and dif-
ferences across countries. This research examines
the extent to which similarities and differences
exist in the codes of professional conduct of
certified (chartered) accountants across different
countries. This comparison provides important
information about the commonality of ethical
values of professional accountants across different
countries.
Elders (1976) suggests that certain attitudes
are culture free. Donaldson (1989) states that
economic systems cannot survive without the
A Cross-Country Comparison
of the Codes of Professional
Conduct of Certified/
Chartered Accountants
Journal of Business Ethics 35: 111–129, 2002.
© 2002 Kluwer Academic Publishers. Printed in the Netherlands.
S. T. Jakubowski
P. Chao
S. K. Huh
S. Maheshwari