Grey matters ethical dilemma: Continuing professional dishonesty – the verdict

Read the CISI's verdict and readers' comments on the ethical dilemma that appears in the July 2019 print edition of The Review

Read the July 2019 dilemma

This Grey Matter, published in the July 2019 print edition of The Review, presents a dilemma for a CISI Chartered member, Chris, who suspects that his manager, also a Chartered MCSI, is claiming CPD for events at which she has not remained for the duration.

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Suggested solutions and results

  1. Speak to Joe, and establish if Monica lets him know when she has had to leave training sessions early. If she does not, Chris should inform the learning and development manager that Monica has been leaving internal CPD training sessions early. (57%)
  2. He should do nothing – this is not his responsibility and Monica is responsible for her own learning and development. Besides, everyone has busy periods where they are unable to dedicate huge amounts of time to attend training sessions. (5%)
  3. Report his suspicions to the CISI, as they may add Monica to their next CPD audit. (18%)
  4. Approach Monica and indirectly enquire about her CPD (eg, “I had to leave a CPD session early last week, do I need to let anyone know?”), hoping that this will lead to a change in behaviour or perhaps even an explanation. (20%)

Responses received: 427

The CISI verdict

Chris has found himself in an awkward situation, where his position as a CISI member and an employee of Hardworking Investments (in particular, as a member of the Investments Team led by Monica) seem to be in conflict.

Option 4, the second most popular solution, allows Chris to gather further information from Monica before taking action. However, as one commenter astutely points out, it may lead to further trouble as “he’s going to have to lie to Monica about leaving a session early, or actually leave a session early to be able to tell the truth to Monica about doing so”.

The CISI’s CPD auditing system relies on trust, as individuals and firms upload and verify CPD records and attendance in accordance with the CISI’s motto ‘My Word is My Bond’. However, some commenters recognise that the weakness in a firm’s internal attendance logging leaves the system open to manipulation, and could be tightened up in order to reduce actual or perceived misconduct.

For that reason, our recommended option is Option 1. Should it be established that Monica has deliberately claimed CPD for events which she did not attend in full, the firm should report this to CISI so further enquiries can be made, which may result in disciplinary investigation.

Selection of comments

“I believe that it is Joe's competence as attendance taker that is in question as he is logging attendance as internal training. Chris has identified a control issue and the solution might be an entry and exit sign off or quiz if taking the subtle approach. Weakness is in Human Resources.”

“Option 1. Without speaking to Joe, Chris has no idea whether or not Joe is logging Monica's attendance. Monica may only be 'making an appearance' to support the events and looking after her own CPD independently.”

“Option 1 seems a bit big-brotherish to me; option 4 more subtle.”

“I agree that option 4 is OK as the first step: at the moment Chris has no idea whether or not Monica is doing anything wrong. She may have already told Joe she was leaving early and might not have claimed CPD hours. If, after talking with Monica, he's more sure she hasn't told Joe, then option 1. I also agree with the previous comment that this is an HR weakness, so maybe the approach ought to be to make HR aware that their process is open to abuse and suggest they tighten it up.”

“I'd be inclined toward a combination of 4 and 1, in that order. Engage with and give Monica the opportunity to confirm that she has been requesting Joe and HR to reduce CPD credits to .25 hour for the shortened classes she has been attending. (She may well have been). Regardless of her reply, I would also follow through with Joe and HR directly to request confirmation whether anyone had been advising/requesting reduced credits for partial attendance. If it became apparent that Monica had been dishonest, I'd call her out directly and suggest she reconcile the matter with HR directly, or that I would do so on her behalf.”

“Option 1. If he goes for option 4 (the only other realistic choice) he´s going to have to lie to Monica about leaving a session early or actually leave a session early to be able to tell the truth to Monica about doing so.”

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Published: 11 Nov 2019
  • Integrity & Ethics
  • verdict
  • grey matters ethical dilemma
  • CPD
  • continuing professional dishonesty
  • continuing professional development
  • Chartered MCSI

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