CODE OF ETHICS FOR CHARTERED ACCOUNTANTS

1 code OF ETHICS FOR CHARTERED ACCOUNTANTS The " code of ETHICS for CHARTERED ACCOUNTANTS (Revised 2019)" is based on the Handbook of the International code of ETHICS for Professional ACCOUNTANTS , 2018 Edition of the International ETHICS Standards Board for ACCOUNTANTS , published by the International Federation of ACCOUNTANTS (IFAC) in July 2018 and is used with permission of IFAC. Handbook of the International code of ETHICS for Professional ACCOUNTANTS , 2018 Edition July 2018 by the International Federation of ACCOUNTANTS . Contact for permission to reproduce, store or transmit, or to make other similar uses of this document. code OF ETHICS FOR CHARTERED ACCOUNTANTS TABLE OF CONTENTS Page 1 of 263 TABLE OF CONTENTS Historical Background .. 6 Foreword .. 7 Preface .. 8 Part 1 - Complying with the code , Fundamental Principles and Conceptual sFramework.

2 10 Part 2 - CHARTERED ACCOUNTANTS in Business .. 27 Part 3 - CHARTERED ACCOUNTANTS in Practice .. 68 International Independence Standards (Parts 4A and 4B) Part 4A - Independence for Audit and Review Engagement .. 124 Part 4B - Independence for Assurance Engagements Other than Audit and Review ddfEngagements .. 210 Glossary, including Lists of Abbreviations .. 252 Effective Date .. 263 code OF ETHICS FOR CHARTERED ACCOUNTANTS Page 2 of 263 OVERVIEW OF THE code OVERVIEW OF THE code PART 1 COMPLYING WITH THE code , FUNDAMENTAL PRINCIPLES AND CONCEPTUAL FRAMEWORK (ALL CHARTERED ACCOUNTANTS - SECTIONS 100 TO 199) PART 2 CHARTERED ACCOUNTANTS IN BUSINESS (SECTIONS 200 TO 299) (PART 2 IS ALSO APPLICABLE TO INDIVIDUAL CHARTERED ACCOUNTANTS IN PRACTICE WHEN PERFORMING PROFESSIONAL ACTIVITIES PURSUANT TO THEIR RELATIONSHIP WITH THE FIRM) PART 3 CHARTERED ACCOUNTANTS IN PRACTICE (SECTIONS 300 TO 399) (PARTS 4A AND 4B) INTERNATIONAL INDEPENDENCE STANDARDS PART 4A INDEPENDENCE FOR AUDIT AND REVIEW ENGAGEMENTS (SECTIONS 400 TO 899) PART 4B INDEPENDENCE FOR ASSURANCE ENGAGEMENTS OTHER THAN AUDIT AND REVIEW ENGAGEMENTS (SECTIONS 900 TO 999) GLOSSARY (ALL CHARTERED ACCOUNTANTS )

3 code OF ETHICS FOR CHARTERED ACCOUNTANTS TABLE OF CONTENTS Page 3 of 263 TABLE OF CONTENTS HISTORICAL BACKGROUND .. 6 FOREWORD .. 7 PREFACE .. 8 PART 1 - COMPLYING WITH THE code , FUNDAMENTAL PRINCIPLES AND CONCEPTUAL FRAMEWORK .. 10 100 Complying with the code .. 11 110 The Fundamental Principles .. 13 111 Integrity .. 14 112 Objectivity .. 15 113 Professional Competence and Due Care .. 15 114 Confidentiality .. 16 115 Professional Behavior .. 18 120 The Conceptual Framework .. 19 PART 2 - CHARTERED ACCOUNTANTS IN BUSINESS .. 27 200 Applying the Conceptual Framework CHARTERED ACCOUNTANTS in Business .. 28 210 Conflicts of Interest .. 33 220 Preparation and Presentation of Information .. 36 230 Acting with Sufficient Expertise .. 42 240 Financial Interests, Compensation and Incentives Linked to Financial Reporting and Decision Making .. 44 250 Inducements, Including Gifts and Hospitality.

4 46 260 Responding to Non-Compliance with Laws and Regulations .. 53 270 Pressure to Breach the Fundamental Principles .. 64 PART 3 - CHARTERED ACCOUNTANTS IN PRACTICE .. 68 300 Applying the Conceptual Framework CHARTERED ACCOUNTANTS in Practice .. 69 310 Conflicts of Interest .. 77 320 Professional Appointments .. 84 321 Second Opinions .. 89 330 Fees and Other Types of Remuneration .. 90 340 Inducements, Including Gifts and Hospitality .. 92 350 Custody of Client Assets .. 99 code OF ETHICS FOR CHARTERED ACCOUNTANTS Page 4 of 263 TABLE OF CONTENTS 360 Responding to Non-Compliance with Laws and Regulations .. 100 370 Public Notices, Announcements and Communications Undue Publicity be Avoided .. 117 INTERNATIONAL INDEPENDENCE STANDARDS (PARTS 4A AND 4B) PART 4A - INDEPENDENCE FOR AUDIT AND REVIEW ENGAGEMENTS .. 124 400 Applying the Conceptual Framework to Independence for Audit and Review Engagements.

5 125 410 Fees .. 140 411 Compensation and Evaluation Policies .. 144 420 Gifts and Hospitality .. 145 430 Actual or Threatened Litigation .. 146 510 Financial Interests .. 147 511 Loans and Guarantees .. 153 520 Business 155 521 Family and Personal Relationships .. 157 522 Recent Service with an Audit Client .. 161 523 Serving as a Director or Officer of an Audit Client .. 163 524 Employment with an Audit Client .. 164 525 Temporary Personnel Assignments .. 168 540 Long Association of Personnel (Including Partner Rotation) with an Audit 169 600 Provision of Non-Assurance Services to an Audit Client .. 175 601 Accounting and Bookkeeping Services .. 180 602 Administrative Services .. 183 603 Valuation Services .. 184 604 Tax Services .. 186 605 Internal Audit Services .. 192 606 Information Technology Systems Services .. 196 607 Litigation Support Services.

6 198 608 Legal 199 609 Recruiting Services .. 201 610 Corporate Finance Services .. 203 code OF ETHICS FOR CHARTERED ACCOUNTANTS TABLE OF CONTENTS Page 5 of 263 800 Reports on Special Purpose Financial Statements that Include a Restriction on Use and Distribution (Audit and Review Engagements) .. 206 PART 4B - INDEPENDENCE FOR ASSURANCE ENGAGEMENTS OTHER THAN AUDIT AND REVIEW ENGAGEMENTS .. 210 900 Applying the Conceptual Framework to Independence for Assurance Engagements Other than Audit and Review Engagements .. 211 905 Fees .. 220 906 Gifts and Hospitality .. 222 907 Actual or Threatened Litigation .. 223 910 Financial Interests .. 224 911 Loans and Guarantees .. 228 920 Business 230 921 Family and Personal Relationships .. 232 922 Recent Service with an Assurance Client .. 236 923 Serving as a Director or Officer of an Assurance Client.

7 238 924 Employment with an Assurance Client .. 239 940 Long Association of Personnel with an Assurance Client .. 242 950 Provision of Non-Assurance Services to Assurance Clients Other than Audit and Review Engagement Clients .. 245 990 Reports that Include a Restriction on Use and Distribution (Assurance Engagements Other than Audit and Review Engagements) .. 249 GLOSSARY, INCLUDING LISTS OF ABBREVIATIONS .. 252 EFFECTIVE DATE .. 263 code OF ETHICS FOR CHARTERED ACCOUNTANTS Page 6 of 263 HISTORICAL BACKGROUND HISTORICAL BACKGROUND 1969-70 "Green Book" became part of Members' Handbook July 1990 IFAC code of ETHICS for Professional ACCOUNTANTS was adopted for the first time April 2000 code of ETHICS was revised by Council February 2003 Section 7 'Publicity and Advertising by CHARTERED ACCOUNTANTS ' was changed August 2004 code of ETHICS was amended by Council May 2005 Section 9 'Independence' and Definitions were replaced with new IFAC requirements May 2008 code of ETHICS was revised by Council April 2015 code of ETHICS was revised by Council code OF ETHICS FOR CHARTERED ACCOUNTANTS FOREWORD Page 7 of 263 FOREWORD The accounting profession has a vital role in society.

8 The accounting profession s unwavering commitment to serve public interest is like an unbreakable chain, running throughout our profession, connecting all of us. The recognition of the value that the profession brings to the society translates into the public trust invested in the profession. Our commitment to serve public interest is a huge responsibility, however, it is the chief attribute through which we have generated goodwill and great standing for our profession over the centuries. Importantly, the profession has to continuously reinforce and elevate its goodwill in the evolving and challenging business and regulatory environment. The significance and the role of ethical practices has become more and more central. Our Institute s vision defines and dictates that professional excellence can only be achieved by upholding the principles of integrity, transparency and accountability.

9 To fulfill its vision, the Institute sets the standards of professional ETHICS and professional behaviour for CHARTERED ACCOUNTANTS . These ethical standards set out the professional responsibilities and duties owed by CHARTERED ACCOUNTANTS to their clients, employers, the authorities and the public at large. The Institute is a member of the International Federation of ACCOUNTANTS (IFAC). It is committed to the IFAC s broad objective of developing and enhancing a coordinated and coherent worldwide accountancy profession with common standards. In this regard, the Institute, as an obligation of its IFAC membership, is obliged to support the work of IFAC by: a) informing its members of every pronouncement developed by IFAC, and b) implementing to the extent possible under local circumstances. IFAC has issued the restructured code of ETHICS for Professional ACCOUNTANTS which includes substantive revisions and is completely rewritten under a new structure and drafting convention.

10 The restructured code has been issued after extensive research and global stakeholder consultation. The Council takes great pleasure in the adoption of the revised code of ETHICS for CHARTERED ACCOUNTANTS that is based on the IFAC restructured code of ETHICS . The revised code of ETHICS for CHARTERED ACCOUNTANTS contains all-around and multifaceted improvements, including the code 's structure and applicability, formatting and drafting, reinforced conceptual framework and ethical requirements and guidance. Our members are expected to adhere to the ethical requirements of the restructured code of ETHICS and exhibit the highest standards of ETHICS and professional conduct that are expected of our profession. Jafar Husain President Karachi, September 30, 2019 code OF ETHICS FOR CHARTERED ACCOUNTANTS Page 8 of 263 PREFACE PREFACE The revised IESBA code In April 2015, the Institute's last code of ETHICS was revised and issued to members.