Gifts and Hospitality. • Pressure related to non-compliance with laws and regulations: o Pressure to overlook potential breaches of environmental or safety regulations applicable to a sustainability assurance client. • Pressure related to level of fees: o Pressure exerted by a superior or a colleague of a sustainability assurance provider to provide professional services at a fee level that does not allow for sufficient and appropriate resources (including human, technological and intellectual resources) to perform the services in accordance with technical and professional standards.
5270.3 A3 Factors that are relevant in evaluating the level of threats created by pressure include: • The intent of the individual who is exerting the pressure and the nature and extent of the pressure. • The application of laws, regulations, and professional standards to the circumstances. • The culture and leadership of the firm including the extent to which they reflect or emphasize the importance of ethical behavior and the expectation that personnel will act ethically. For example, a corporate culture that tolerates unethical behavior might increase the likelihood that the pressure would result in a threat to compliance with the fundamental principles. • Policies and procedures, if any, that the firm has established, such as ethics or human resources policies that address pressure. 5270.3 A4 Discussing the circumstances creating the pressure and consulting with others about those circumstances might assist the sustainability assurance provider to evaluate the level of the threat. Such discussion and consultation, which requires being alert to the principle of confidentiality, might include: • Discussing the matter with the individual who is exerting the pressure to seek to resolve it. • Discussing the matter with the practitioner’s superior, if the superior is not the individual exerting the pressure. • Escalating the matter within the firm, including when appropriate, explaining any consequential risks to the firm, for example with: o Higher levels of management. o Internal or external auditors. o Those charged with governance. • Disclosing the matter in line with the firm’s policies, including ethics and whistleblowing policies, • using any established mechanism, such as a confidential ethics hotline. • Consulting with: o A colleague, superior, human resources personnel, or another sustainability assurance provider; o Institute or industry associations; or o Legal counsel. 5270.3 A5 An example of an action that might eliminate threats created by pressure is the sustainability assurance provider’s request for a restructure of, or segregation of, certain responsibilities and duties relating to the professional services performed for a sustainability assurance client so that the practitioner is no longer involved with the individual or entity exerting the pressure.