Corporate Secretarial Practice, Ethics and Professional Conduct
What the exam tests
This domain tests the standards expected of a chartered secretary: the ethical framework, handling of confidential information and conflicts, anti-money-laundering and beneficial-ownership duties, and sound practice management.
Core rules
- Core ethical principles: integrity, objectivity, professional competence and due care, confidentiality and professional behaviour. The ICSAN code and disciplinary machinery apply to members.
- Confidentiality is not absolute: disclosure is permitted where required by law, by the member's professional body or with the client's authority.
- Conflicts of interest must be disclosed and managed, and the secretary should recuse from work where a personal interest exists. Loyalty runs to the company as a whole, not to the managing director or a dominant shareholder.
- Beneficial ownership must be established and filed with the CAC; secretaries in relevant sectors must comply with anti-money-laundering obligations, including customer due diligence and suspicious transaction reporting.
- Data protection under the Nigeria Data Protection Act 2023 governs the handling of members' and employees' personal data in registers and filings.
- Good practice: engagement letters, controlled minute books, filing calendars, proper delegation and escalation, and a documented whistleblowing channel.
Worked example
A managing director asks the secretary to backdate board minutes to cover a decision taken late. The secretary should refuse, record the true date, note the request and escalate to the board chair or audit committee. Backdating is falsification, breaches integrity and objectivity, and can mislead auditors and regulators.
Traps
Treating loyalty to a director as loyalty to the company; releasing the register of members without verifying the applicant's entitlement; ignoring beneficial-ownership filings; assuming confidentiality covers concealment of wrongdoing.