Given that most of my concerns were misinterpreted, partly addressed or just ignored, a lengthy response was required:
“Dear Andrea
Thank you for your prompt reply to my comments.
I fear that, unlike Sarah Reay’s reply to my question about using a UAE delegation member to discuss COP27, you have not really addressed my arguments in any detail or in any comprehensive way. Let me clarify my main points in the context of your reply:
- Intention of the Certificate
I quote from the ICAEW’s website on the subject:
“ICAEW’s Sustainability Certificate equips accountants and other finance professionals with the practical knowledge and skills to integrate sustainability reporting into their organisations.
After completion of ICAEW’s online certificate, finance professionals will be able to identify climate-related risks and incorporate performance and financial metrics into their risk management, financial planning and analysis, and ESG / sustainability reporting.”
If the Certificate “does not, and was never intended to, create sustainability experts” then surely its publicity should not strongly imply that it does? You could engage Professor Jacqueline McGlade, Greta Thumberg, Caroline Lucas and Dame Ellen Macarthur to lead the course, and it still could not do more than effect a general introduction to the subject. Please do not mislead delegates into believing this is something that it plainly cannot be.
Limited knowledge
Yes indeed, and after this course they will still have (rather less) limited knowledge.
Opening doors
To be fair I think you mean doors in the delegates’ minds, but this does bring me to the heart of my concerns. Are you not in grave danger of deluding your delegates into believing that they are competent to engage with the public on sustainability issues after a mere 15 hours of training, and then conspiring to delude the public by issuing those delegates with a certificate certifying their competence in the field? “Do not undertake work that you are not competent to do” is a vital part of our excellent ethical framework – are you not encouraging people to do precisely that by instilling in them a grossly exaggerated sense of competence?
Encouraging further engagement
Oh yes, spot on. This is exactly what a 15-hour course on sustainability should be doing. But don’t give people a certificate that they can brandish in the faces of the public as evidence that they have more than the vaguest clue what they are doing in this area, based on an introductory course.
Programme development
I have absolutely no doubt based on past experience that the course content is excellent. 17 years of experience is an admirable background for a course presenter. It is not quality I have an issue with (and how could I, not having seen the course materials or done the course?) but quantity. There is a serious mismatch here between what can be physically instilled about sustainability in 15 hours and the implications of certificating members on the basis of the course. I am afraid that what you are doing is tantamount to teaching a 4-year-old child to read and giving them an English Literature A level or teaching them to count and giving them a maths degree. The name of the ICAEW still (rightly) carries enormous prestige, and you cannot put that prestige at risk by creating a situation where members (in all good faith) offer sustainability services to the public that they are not competent to provide.
Delegate feedback
Has, I am sure, been extremely positive, but do they understand the limitations of what they are being taught in terms of their capacity to advise in these areas?
Pricing
An issue I note that you did not address at all. The 110-hour Level 2 Certificate in Understanding Climate Change that I and a colleague are currently undertaking is provided free by our local Further Education College via our local Chamber of Commerce. On the back of several years’ diligent study of these issues, this is an appropriate quantity and level of material to justify certification – we both undertook the course because we are largely self-taught and wanted to fill in any gaps in our knowledge. But, of course, certification by Hopwood College, Middleton (admirable institution as it is) does not carry a fraction of the weight of certification by the ICAEW, yet the course is infinitely more in depth and comprehensive than a 15-hour course can ever be. Yet you are charging £225 + VAT for your course, which again contributes to the delusion that what comes out of the course is something worth paying a significant sum for. Given that this is in reality a mere introduction to sustainability, that is again highly misleading to delegates.
Summary
- The ICAEW is putting its enviable brand at risk by offering this certificate.
- Delegates are being given a delusion of competence, which will lead them to undertake work they are not competent to do.
- The public is being misled into believing that they are dealing with a sustainability expert, when they palpably are not.
- You are charging delegates for something that is available in much greater depth elsewhere for free and charging them an amount that suggests that something meaningful in terms of competence for public engagement comes out of the course, when this is simply impossible in a course of this duration.
- You are seriously misrepresenting the course in your publicity material.
- You are in grave danger of ‘skill-washing’, by suggesting or implying to the public that members are competent to advise on matters that they are not.
- From a purely selfish perspective, you are debasing and undermining the years of work that my colleagues and I have done to render ourselves competent to advise on sustainability. And even with that background, we still refer our clients for the vast majority of sustainability issues that we identify to experts in that particular niche of sustainability rather than undertaking work that we may not be competent to do. Muddying the waters for the public in this manner is unconscionable, and that is why I am seriously considering resigning my 39-year-old ICAEW membership. And I fear that your reply has done little or nothing to change my mind in this respect. Just imagine the degree of disenchantment and anger that is required to achieve that undesirable objective.
Conclusions
Not wishing to be accused of being wholly negative, I have proposals for correcting this position going forward:
- Re-brand the course as “An Introduction to Sustainability.”
- Stop issuing a certificate for it,
- Stop charging for it.
- Develop a comprehensive sustainability course for those interested in advising the public on the subject, of a duration approaching the 110 hours of the Level 2 Understanding Climate Change course, charge whatever you see fit for it and certificate it. Also, offer links to the many organisations that will provide general sustainability courses for free.
- Remove the misleading advertising material from the website and replace it with a true representation of what the course is.
- Et voila, the brand is intact, no-one is being misled into breaching the “competent to do” ethical requirement, no-one is being ripped off, and no member of the public is misled into taking sustainability advice from someone not competent to give it, and you are still empowering those of your members who are sufficiently dedicated to brandish their hard-earned certificate from the course at 4 as a true reflection of their ability to advise on sustainability issues.
Which brings me to Friday’s session. I will be publishing your reply in full on my blog because I believe in the right to reply – I did the same with Sarah’s. Does the ICAEW believe in the right to reply? Are you prepared to give me a 5-minute presentation slot on Friday to enumerate my concerns and give the ICAEW the chance in a (semi) public forum to answer them? If so, I will regard that as sufficient evidence that the ICAEW is taking this issue seriously, and I will happily abide by the views of the assembled delegates and dismiss any thoughts of resignation. If not, I will be obliged to enumerate my concerns through the only medium available to me, the Q&A feature, by raising a series of questions based on the above. I don’t think I can be much fairer than warning you what I am going to ask in advance, whatever medium is available to me to do so.
Thanks & best wishes
Mark Simpson
The Green Accountants
Big Hand Group
